Article 186. Collection of tax debts of a taxpayer (tax agent) from the accounts of his debtors of the Tax Code of the Republic of Kazakhstan

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 1. The collection of tax arrears is applied to the money held in the bank accounts of its debtors, in case the taxpayer (tax agent) fails to repay the tax arrears in an amount exceeding the maximum amount of tax arrears, after taking a compulsory recovery measure at the expense of the money held in its bank accounts.

 For the purposes of this article, a debtor is an individual, a legal entity, a structural subdivision of a legal entity, a non-resident operating in the Republic of Kazakhstan through a permanent establishment, an individual entrepreneur, a person engaged in private practice who is in debt to a taxpayer (tax agent).

 2. In order to identify debtors of a taxpayer (tax agent), the tax authority has the right:

 1) use the data of the tax authority's information system;

 2) conduct a tax audit of the taxpayer (tax agent) on the issue of determining mutual settlements between him and his debtors and a counter tax audit of debtors.

 3. The tax authority sends a notification to the debtor confirming the receivable.

 4. The debtor submits to the tax authority, on paper or electronically, an act of reconciliation of settlements drawn up jointly with the taxpayer (tax agent), and (or) if it is impossible to draw up an act of reconciliation of settlements as of the date of receipt of the notification, documents confirming settlements with the taxpayer.

 5. In case of non-fulfillment of the notification of confirmation of the amount of accounts receivable by the tax authority:

 1) a tax audit of debtors is being conducted;

 2) an order is issued to suspend spending operations on bank accounts within one business day following the expiration date of such notification.

 6. The tax authority issues collection orders to the debtor's bank accounts for the amount of the taxpayer's (tax agent's) tax debt within the limits of the receivable, confirmed by one of the following documents:

 1) an act of reconciliation of mutual settlements;

 2) an act of tax audit confirming the amount of accounts receivable;

 3) a court decision that has entered into legal force.

 7. Collection orders issued to the debtor's bank accounts are subject to revocation upon repayment of tax arrears by the taxpayer (tax agent) or the debtor.

 8. An amount excessively debited from the debtor's bank accounts opened with several banks in excess of the amount specified in the collection order is subject to refund to the same debtor's bank account without a taxpayer's (tax agent's) application.

The Code of the Republic of Kazakhstan dated July 18, 2025 No. 214-VIII SAM.

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Republic of Kazakhstan

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From January 1, 2026, to invalidate the Code of the Republic of Kazakhstan dated December 25, 2017 "On Taxes and Other Mandatory payments to the Budget" (Tax Code) in connection with the entry into force of the Tax Code dated July 18, 2025 No. 214-VIII SAM.

Article 186. Procedure for the appointment and conduct of a thematic audit of the Code on Taxes and Other Mandatory Payments to the Budget (Tax Code) of the Republic of Kazakhstan

1. When considering a complaint from a taxpayer (tax agent), the authorized body may, if necessary, appoint a thematic audit.

2. The document on the appointment of a thematic audit is drawn up in writing with an indication of the issues to be reviewed.

At the same time, the conduct of a thematic audit may not be entrusted to the tax authority that conducted the tax audit, the results of which are being appealed, except in the case when the appealed tax audit was conducted by an authorized tax authority.

3. A thematic audit is conducted in accordance with the procedure and terms established by this Code. At the same time, a thematic audit must be initiated no later than ten working days from the date of receipt by the tax authority of the document on conducting such an audit.

4. If there is insufficient clarity or completeness of the data, as well as new questions arise regarding circumstances and documents previously verified during the thematic audit, the authorized body has the right to appoint it again.

5. The decision on the results of consideration of the complaint is made taking into account the results of thematic and (or) repeated thematic inspections. At the same time, if the authorized body does not agree with the results of such inspections, it has the right not to take them into account when deciding on the complaint, however, such disagreement must be motivated.

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