The State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan clarifies the procedure for applying the time limits for recognizing a non-resident's liabilities under advance payments (prepayments) received as income.

Before 1 January 2026, in accordance with tax legislation, a non-resident's liabilities under an advance payment (prepayment) received that were not fulfilled within 24 months from the date of payment of the advance were recognized as the non-resident's income from sources in the Republic of Kazakhstan.

As of 1 January 2026, paragraph 1 of Article 679 of the Tax Code of the Republic of Kazakhstan reduced this period from 24 to 12 months.

Accordingly:

• for advance payments (prepayments) paid to a non-resident before 1 January 2026, the 24-month period from the date of payment of the advance (prepayment) applies;
• for advance payments (prepayments) paid to a non-resident on or after 1 January 2026, the 12-month period from the date of payment of the advance (prepayment) applies.

Accordingly, if a non-resident fails to fulfill its liabilities under an advance payment received within the established period, the amount of such unfulfilled liabilities is recognized as the non-resident's income from sources in the Republic of Kazakhstan in the manner prescribed by tax legislation.

Example. If an advance payment to a non-resident was made in July 2025, the 24-month period applies for purposes of income recognition. If the advance payment was made in July 2026, the 12-month period applies.

The State Revenue Committee draws taxpayers' attention to the need to take into account the date of payment of the advance (prepayment) when determining the applicable period.

Source : https://www.gov.kz/memleket/entities/kgd/press/news/details/1275090?lang=ru