Commentary to article 471. Failure by local executive bodies and other authorized state bodies to comply with the obligations established by the tax legislation of the Republic of Kazakhstan and the Code of Administrative Offences of the Republic of Kazakhstan
1. Non-transfer, late or incomplete transfer by local executive bodies or authorized state bodies of the amounts of taxes and other mandatory payments to the budget to be transferred to the budget in accordance with the tax legislation of the Republic of Kazakhstan by the bodies specified in this part, -
they impose a fine on officials in the amount of thirty monthly calculation indices.
2. Failure, late, unreliable or incomplete submission by local executive bodies and other authorized state bodies of information determined by the tax legislation of the Republic of Kazakhstan for submission to state revenue authorities, -
they impose a fine on officials in the amount of thirty monthly calculation indices.
3. Failure by authorized state and local executive bodies to comply with the requirements for the elimination of violations identified by the results of tax control and specified in the act of control, -
entails a fine for officials in the amount of thirty monthly calculation indices.
4. Actions (inaction) provided for in the first and second parts of this Article, committed repeatedly within a year after the imposition of an administrative penalty, -
they impose a fine on officials in the amount of sixty monthly calculation indices.
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The commented article establishes administrative responsibility for failure by local executive bodies and other authorized state bodies to fulfill the duties assigned to them by the tax legislation of the Republic of Kazakhstan for the full and timely transfer of collected taxes and payments to the budget to the state budget and the proper provision of information on collected taxes and payments to the budget to the state revenue authorities.
The generic object of offenses provided for in Article 471 of the Administrative Code is the tax administration procedure established in the legislation of the Republic of Kazakhstan and protected by the state.
The direct object of administrative offenses provided for in the commented article is the procedure established by the Tax Code of the Republic of Kazakhstan and protected by the state for collecting and crediting taxes and other mandatory payments to the budget, compiling and submitting accounting documents on them to the state revenue authorities and executing tax control acts.
The subjects of the offense provided for in art. 471 of the Administrative Code, by virtue of the direct indication of this in the sanctions of the commented article, are officials of local executive bodies and authorized state bodies who, at the request of the Tax Code of the Republic of Kazakhstan, are required to directly receive (collect) taxpayers who pay taxes and payments to the budget, transfer money collected from taxes to the budget, are required to issue receipts to taxpayers in return for taxes collected in accordance with the prescribed form and submit reports to the state revenue authorities on receipts used, taxes collected, their amounts and payers.
According to the note to Article 30 of the Administrative Code, officials in the Administrative Code are recognized as persons who, permanently, temporarily or by special authority, perform or were performing at the time of the commission of an administrative offense the functions of a government representative or who were performing or were performing at the time of the commission of an administrative offense organizational, administrative or economic functions in state institutions, quasi-public sector entities, local governments.
At the same time, at the request of the norm of Article 30 of the Administrative Code, an official is brought to administrative responsibility if he commits an administrative offense in connection with non-fulfillment or improper performance of his official duties. In the absence of this circumstance, an official guilty of committing an administrative offense is liable on general grounds.
According to the legislative definition, a local executive body (akimat) is a collegial executive body headed by the akim of a region, a city of republican significance and the capital, a district (city of regional significance), exercising local government and self–government in the relevant territory within its competence. Accordingly, the akim of a district in a city, city of district significance, settlement, village, rural district is an official of the relevant district (city) akimat (local executive body) on the territory of the relevant administrative-territorial unit and acts on his behalf without a power of attorney in relations with government agencies, organizations and citizens. Akims, as officials of local executive bodies, within the competence provided for them by the legislation of the Republic of Kazakhstan, facilitate the collection of taxes and other mandatory payments to the budget.
Tax collection is organized by local executive bodies in those administrative-territorial units in which there are no state revenue authorities. In this capacity, local executive bodies act as tax collectors, acting on behalf of and in the interests of the State.
At the same time, local executive bodies do not collect all taxes of individuals, but only those that must be paid by individual taxpayers on their own. Such taxes, in accordance with the Tax Code of the Republic of Kazakhstan, include property tax, vehicle tax and land tax. These taxes are levied by local executive authorities only if they are paid in cash. Local executive bodies are not authorized to collect other taxes, as well as taxes that are paid by taxpayers independently by wire transfer to the state budget through banking and equivalent cash settlement organizations.
In addition to the taxes mentioned above, the state in the Tax Code of the Republic of Kazakhstan directly authorizes individual government agencies to receive cash from taxpayers in payment of certain types of fees, fees and state duties.
Accordingly, such authorized state bodies are required by the Tax Code of the Republic of Kazakhstan to accept cash and transfer it to the state budget within the time limits and procedures established for this purpose in the Tax Code of the Republic of Kazakhstan.
Cases of collection and subsequent transfer to the state budget of fees, fees and state duties of this kind are legally provided for in cases of collection and subsequent transfer to the state budget.: 1) collection for the passage of motor vehicles through the territory of the Republic of Kazakhstan; 2) state duty; 3) consular fee; 4) fees for forest use; 5) fees for the use of specially protected natural areas.
Accordingly, the authorized state bodies for collecting such mandatory payments to the budget are the authorized state body in charge of management in the field of motor transport, authorized state bodies performing notarial acts, registration actions, issuance of documents, permits, the Ministry of Foreign Affairs, diplomatic missions or consular offices, state forest owners, environmental organizations.
As a general rule, when individuals pay the amount of state duty, consular fee, travel fee on the territory of the Republic of Kazakhstan and other payments to the budget in cash, such amounts of payments are accepted on the basis of strict reporting forms and submitted by authorized government agencies to second-tier banks or organizations engaged in certain types of banking operations no later than the next business day. from the day on which the money was accepted for subsequent transfer to the budget. If the daily cash receipts are less than 10 times the MCI, the money is deposited once every three business days from the day on which the money was received.
At the same time, local executive bodies and authorized state bodies themselves, which are charged with collecting taxes from taxpayers and crediting taxes to the budget (when they are legal entities), are not subjects of administrative responsibility under the commented article.
The heads of local executive bodies and authorized state bodies bear administrative responsibility under the commented article as officials in cases where the performance of duties required by the Tax Code of the Republic of Kazakhstan falls directly within their competence, as well as in cases where they have not previously identified specific subordinate officials responsible for the collection and transfer of taxes and other payments to the budget, providing information to the state revenue authorities on taxes collected and transferred and payments to the budget, as well as for meeting the requirements to eliminate violations identified by the state revenue authorities based on the results of tax control.
Accordingly, the commented norm does not apply to other participants in tax legal relations (taxpayers, tax agents, payment operators, tax representatives and officials of state revenue bodies).
The subjective side of the acts provided for in Article 471 of the Administrative Code is characterized by guilt in the form of intent or negligence of the officials who committed the offenses. The guilt of an official is revealed by his mental attitude towards the illegal acts committed by him.
Part 1 of the commented article establishes administrative liability for non-transfer, late or incomplete transfer by local executive bodies or authorized state bodies of the amounts of taxes and payments to the budget to be transferred by these bodies to the budget in accordance with the tax legislation of the Republic of Kazakhstan.
The objective side of the offense provided for in Part 1 of Article 471 of the Administrative Code is that the offender commits culpable unlawful acts in the form of late or incomplete transfer of collected taxes and payments to the budget, or culpable unlawful inaction in the form of non-transfer of collected taxes and payments to the budget.
The legal obligation to collect taxes from taxpayers and transfer them to the budget, issue receipts for taxes collected to taxpayers and submit reports on this to the tax authorities is the subjective responsibility of local executive bodies and authorized state bodies as tax collectors. This obligation arises for tax collectors within the framework of organizational (procedural) tax relations in cases explicitly specified in the Tax Code of the Republic of Kazakhstan.
Taxes collected from taxpayers must be transferred in full by officials of local executive bodies and authorized state bodies to the state budget through authorized banking and equivalent organizations within the time limits established for this purpose in the Tax Code of the Republic of Kazakhstan. Late transfer of collected taxes to the state budget (transfer beyond the time limits set for this in the Tax Code of the Republic of Kazakhstan), as well as incomplete transfer (transfer of part of the collected taxes) form an independent completed offense provided for in Part 1 of the commented article, regardless of the subsequent transfer of collected taxes to the budget.
A prerequisite for bringing to administrative responsibility under Part 1 of the commented article is the establishment of the fact that an official of a local executive body or an authorized state body received cash from taxpayers in advance and then did not transfer it or incomplete or untimely transfer to the budget.
Failure to transfer taxes to the budget due to their non-receipt from taxpayers does not constitute an administrative offense under Part 1 of Article 471 of the Administrative Code. A taxpayer has the right to pay certain types of taxes and other mandatory payments both in non-cash form directly to the state budget through authorized banking and equivalent organizations, and in cash through local executive bodies and authorized state bodies by transferring money to authorized officials of these bodies in cases directly provided for by the Tax Code of the Republic of Kazakhstan. If a taxpayer fulfills his tax obligation in a non-cash form, taxes are considered to have been paid directly to the state budget and, accordingly, local executive bodies and authorized state bodies have no obligation or authority to collect these taxes and payments in cash. In case of non-fulfillment by a taxpayer of his tax obligations to the state, local executive bodies and authorized state bodies are also not liable under part 1 of the commented article.
The composition of the offense provided for in Part 1 of the commented article is formal. In order to calculate and impose a fine on an offender under Part 1 of the commented article, it is not necessary to establish the fact and amount of damage caused to the state by non-transfer, incomplete or late transfer of collected taxes and payments to the budget. However, when brought to administrative responsibility under part 1 of the commented article, if it is established that damage has been caused to the state by non-transfer, incomplete or untimely transfer of money collected from taxes to the budget, such damage must be presented to the offender for compensation according to the rules of art. 59 of the Administrative Code. As a general rule, Part 5 of Article 55 of the Administrative Code, the imposition of an administrative penalty does not release a person from fulfilling the obligation for non-fulfillment of which the specified penalty was imposed, eliminating violations and compensating for damage.
For committing an offense provided for in Part 1 of the commented article, an official of a local executive body or an authorized state body responsible for the full and timely transfer of cash collected from taxes to the state budget is liable to a fine. The fine is levied from the official of the local executive body or an official of the authorized state body at the expense of his personal funds and cannot be collected from the local executive body or from the authorized state body or paid at their expense.
The amount of the fine for committing an offense under Part 1 of Article 471 of the Administrative Code is fixed, amounts to 30 MCI and is not subject to change by the body imposing it.
A fine is imposed by the state revenue authorities or the court, in the case of an administrative offense case in court.
Part 2 of the commented article establishes administrative liability for failure to submit, late, unreliable or incomplete submission to the state revenue authorities of information to be submitted at the request of the tax legislation of the Republic of Kazakhstan.
The objective side of the offense provided for in Part 2 of Article 471 of the Administrative Code is expressed in the commission by the offender of guilty unlawful acts in the form of incomplete or untimely submission to the state revenue authorities of information about taxes collected and their payers, or submission of false information about this, as well as inaction in the form of failure to provide such information when the obligation to provide it is established by the tax legislation of the Republic of Kazakhstan.
The legal obligation to provide information to the state revenue authorities on taxes collected and payments to the budget and their payers is the subjective responsibility of local executive bodies and authorized state bodies as tax collectors. This obligation arises for tax collectors within the framework of organizational (procedural) tax relations in cases directly provided for in the Tax Code of the Republic of Kazakhstan.
Information on taxes collected from taxpayers and payments to the budget must be fully and timely submitted by officials of local executive bodies and authorized state bodies to state revenue bodies in accordance with the reporting form established by the authorized body in accordance with the Tax Code of the Republic of Kazakhstan. The delay in submitting information on taxes collected to the state revenue authorities (providing information beyond the time limits set for this in the Tax Code of the Republic of Kazakhstan), as well as their incomplete provision (providing incomplete or incomplete information on taxes collected and their payers) form a complete independent offense provided for in Part 2 of the commented article, regardless of the subsequent providing the state revenue authorities with all information about taxes collected and payments to the budget.
Information about taxes collected and payments to the budget must also correspond to reality. The unreliability of the information contained in the reports and provided to the state revenue authorities (their inconsistency with reality) forms an independent completed offense provided for in Part 2 of the commented article.
If the actions of an official of a local executive body or an authorized state body simultaneously show signs of incomplete, untimely and unreliable provision of information to the state revenue authorities (in the form of appropriate reports), the official should be punished under Part 2 of the commented article for committing one administrative offense, unless such illegal actions contain signs of a repeat commission. violations (see the commentary to part 4 of the commented article). In this case, when classifying the actions of an official as illegal, all the actions committed by him, provided for in part 2 of the commented article, are combined into one part of an administrative offense and are covered by its objective side.
The composition of the offense provided for in Part 2 of the commented article is formal. In order to bring to administrative responsibility under Part 2 of the commented article, it is not necessary to establish the fact and amount of damage caused to the state by failure to provide, incomplete, late provision of information or provision of false information about taxes collected and transferred and payments to the budget. To be held administratively liable under part 2 of the commented article, there is also no need to establish damage from non-transfer, incomplete or late transfer of money collected from taxes to the budget.
In the case of establishing the fact of non-transfer or incomplete or untimely transfer of money collected from taxes to the state budget, along with establishing the fact of non-provision or incomplete, untimely and (or) unreliable provision of information on taxes collected, the qualification of the official's actions and bringing him to justice must follow, according to the rule of Part 1 of Article 58 of the Administrative Code, simultaneously under Part 1 and Part 2 of the commented article as for committing administrative offenses independent of each other.
If the failure to provide information, as well as the provision of incomplete and (or) unreliable information about taxes collected and payments to the budget and the simultaneous non-transfer or incomplete transfer of taxes to the budget were committed for the purpose of their appropriation by an official, then, depending on the amount of money appropriated, this act should be qualified under other relevant articles of the Criminal Code. or the Administrative Code.
In case of non-receipt of taxes and payments to the budget from taxpayers, information on them should not be provided to the state revenue authorities. Accordingly, failure to provide information in such cases does not constitute an administrative offense under Part 2 of the commented article. However, if the information was provided by an official to the state revenue authorities and such information provided does not correspond to reality in cases where taxes and payments to the budget were not actually received from taxpayers, administrative liability under Part 2 of the commented article is charged as providing false information when establishing the guilt of an official of a local executive body or an authorized state body. In the absence of the official's fault, he should not be held administratively liable under Part 2 of the commented article.
For committing an offense provided for in Part 2 of the commented article, an official is subject to punishment in the form of a fine. The fine is levied from the official of the local executive body or the authorized state body at the expense of his personal funds and cannot be collected from the local executive body or from the authorized state body or at their expense.
The amount of the fine for committing an offense under Part 2 of Article 471 of the Administrative Code is fixed, amounts to 30 MCI and is not subject to change by the body imposing it.
A fine is imposed by the state revenue authorities or the court, in the case of an administrative offense case in court.
Part 3 of the commented article contains an independent composition of an administrative offense, the objective side of which is expressed in the failure of an official of a local executive body or an authorized state body to comply with the requirements of state revenue authorities to eliminate violations identified by them based on the results of tax control and specified in the relevant control acts.
Control over the activities of authorized state bodies is carried out on the issues of the correctness of calculation, completeness of collection and timely transfer of payments to the budget, as well as the reliability and timeliness of the submission of information to the tax authorities. Control over the activities of local executive bodies is carried out on issues of the correctness of calculation, completeness of collection and timely transfer of payments to the budget, reliability and timeliness of submission of information on property tax, vehicles, land tax and payments to tax authorities. Such control is carried out on the basis of an appropriate decision of the state revenue authority. The period of control should not exceed thirty working days from the date of delivery to the authorized state body of the decision on the appointment of control. The specified period may be extended up to fifty working days by the state revenue authority that appointed the control. Control over the activities of authorized state bodies is carried out no more than once a year.
Accordingly, upon completion of the control by the state revenue authority, an act of control is drawn up, which is handed over to the local executive body or an authorized state body. In the presence of violations identified by the results of control, the state revenue authorities issue a requirement to eliminate violations of the tax legislation of the Republic of Kazakhstan. A requirement to eliminate violations of the tax legislation of the Republic of Kazakhstan is a hard copy notification sent by the state revenue authority to a local executive body or an authorized state body about the need for this body to eliminate violations specified in the control act. Such a requirement is subject to mandatory execution by an official of the local executive body or the authorized state body to which it is presented. Failure to comply with such a requirement entails administrative liability for an official who fails to comply with it under Part 3 of the commented article.
Acts of tax control of state revenue authorities and the requirements set forth in them for the elimination of violations of the tax legislation of the Republic of Kazakhstan are assumed to be legitimate until otherwise established by authorized bodies and officials in accordance with the procedure provided for by the legislation of the Republic of Kazakhstan upon applications (complaints) of interested persons. The illegality of the claims of state revenue authorities and their acts must be established in a higher authority or in court upon a complaint (application) from interested persons whose rights and interests are affected by such acts and requirements. Until the fact of the illegality of acts and demands of state bodies is established in accordance with the procedure established for this by the legislation of the Republic of Kazakhstan, such acts and demands must be executed by the officials to whom they are addressed, unless they are appealed in accordance with the procedure established by law. As a general rule, the submission by interested persons of an application for the cancellation, amendment, addition or suspension of a legal act of individual application to a higher state body or court suspends the validity of the legal act.
The composition of the offense provided for in Part 3 of the commented article is formal. In order to bring an official to administrative responsibility under Part 3 of the commented article, it is not necessary to establish the fact and amount of damage caused to the state by failure to comply with the requirements of the state revenue authorities to eliminate violations identified by the results of tax control and reflected in the control act.
For committing an offense provided for in Part 3 of the commented article, an official of a local executive body or an authorized state body is subject to punishment in the form of a fine. The fine is levied from the official of the local executive body or an official of the authorized state body at the expense of his personal funds and cannot be collected from the local executive body or from the authorized state body or at their expense.
The amount of the fine for committing an offense under Part 3 of Article 471 of the Administrative Code is fixed, amounts to 30 MCI and is not subject to change by the body imposing it.
A fine is imposed by the state revenue authorities or the court, in the case of an administrative offense case in court.
Part 4 of the commented article establishes a more severe penalty for repeated commission by an official of a local executive body or an authorized state body of any of the acts provided for in parts 1, 2 or 3 of the commented article within a year after the imposition of an administrative penalty.
At the same time, the object, the subjective side, and the subjects of the offense provided for in Part 4 of the commented article coincide in their characteristics, respectively, with the object, the subjective side, and the subjects of the offenses provided for in Parts 1, 2, or 3 of Article 471 of the Administrative Code.
In the description of the objective side of the offense provided for in Part 4 of Article 471 of the Administrative Code, a sign of repetition is added to any of the acts provided for in parts 1, 2 or 3 of the commented article.
An offense is considered to have been committed repeatedly if a specific official of a local executive body or an authorized state body has previously committed any of the acts provided for in Parts 1, 2 or 3 of Article 471 of the Administrative Code, has been subjected to administrative punishment for it, and the one-year period during which the person is considered to have been subjected to administrative punishment has not yet expired.
The repetition of an offense is an independent qualifying feature, entailing the qualification of an unlawful act as an independent element of an offense under Part 4 of Article 471 of the Administrative Code.
At the same time, it does not matter which of the illegal actions (inaction) provided for in parts 1, 2 or 3 of the commented article was committed by the official for the second time within a year after he was brought to administrative responsibility. Committing any of them means repetition, even if earlier in the year the official committed a completely different illegal act from those provided for in Parts 1, 2 or 3 of Article 471 of the Administrative Code and was subjected to administrative punishment for it.
For repeated commission of any of the offenses provided for in Parts 1, 2 or 3 of Article 471 of the Administrative Code within a year after the imposition of the penalty, the offender is punished with a fine. The fine is levied from the official of the local executive body or an official of the authorized state body at the expense of his personal funds and cannot be collected from the local executive body or from the authorized state body or at their expense.
The amount of the fine for committing an offense under Part 4 of Article 471 of the Administrative Code is 60 MCI, is fixed and is not subject to change by the body imposing it.
A fine is imposed by the state revenue authorities or the court, in the case of an administrative offense case in court.
Scientific and practical commentary to the Code of the Republic of Kazakhstan on Administrative Offences (article-by-article) from the Author's team:
Bachurin Sergey Nikolaevich, Candidate of Law, Associate Professor – chapter 48 (co-authored with E.M. Khakimov);
Gabdualiev Mereke Trekovich, Candidate of Law – Chapters 11, 21, 22, 23;
Zhusipbekova Ainur Maratovna, M.yu.n. – chapter 13 (co-authored with Karpekin A.V.); chapters 33, 39 (co-authored with Seitzhanov O.T.);
Alexander Vladimirovich Karpekin, Candidate of Law, Associate Professor – chapter 13 (in collaboration with A.M. Zhusipbekova);
Korneychuk Sergey Vasilyevich – chapters 2; chapter 6 (co-authored with O.T. Seitzhanov, E.M. Khakimov); chapter 8; chapter 25 (co-authored with E.M. Khakimov); articles 457-470, 488, 488-1, 491-506; chapters 28, 30, 52;
Ilya Petrovich Koryakin, Doctor of Law, Professor – Chapter 49;
Kisykova Gulnara Bauyrzhanovna, Candidate of Law – chapter 20;
Omarova Botagoz Akimgereevna, Candidate of Law – chapters 17; chapter 18 (co-authored with B.A. Parmankulova); chapters 26, 31; chapter 32 (co-authored with B.A. Parmankulova);
Parmankulova Bayan Askhanbaevna – chapter 18 (co-authored with Omarova B.A.); chapters 19, 32 (co-authored with Omarova B.A.); chapter 43 (co-authored with Tukiev A.S.);
Podoprigora Roman Anatolyevich, Doctor of Law, Professor - Chapter 24, articles 489, 489-1, 490;
Porokhov Evgeny Viktorovich, Doctor of Law – Chapters 14, 15, 16, 29, articles 471-475;
Seitzhanov Olzhas Temirzhanovich, Candidate of Law, Associate Professor, – chapter 4; chapter 5 (co-authored with E. M. Khakimov); chapter 6 (co-authored with S.V. Korneychuk, E.M. Khakimov); chapter 9; chapter 10 (co-authored with B.E. Shaimerdenov, V.V. Filin); chapter 33 (co-authored with Zhusipbekova A.M.); chapter 36 (co-authored with Shaimerdenov B.E.); chapter 39 (co-authored with Zhusipbekova A.M.);
Smyshlyaev Alexander Sergeevich, PhD. – chapters 38, 40, 42, 43-1 (co-authored with A.S. Tukiev); chapter 44;
Aslan Sultanovich Tukiev - Candidate of Law, Associate Professor – chapters 1, 3, 35; chapters 38, 40, 42, (co-authored with A.S. Smyshlyaev); chapter 43 (co-authored with B.A. Parmankulova); chapter 43-1 (co-authored with A.S. Smyshlyaev); chapter 44-1 (co-authored with Shipp D.A.); chapter 45; 46 (co-authored with Shipp D.A.); chapter 47;
Filin Vladimir Vladimirovich, Candidate of Law, Associate Professor – Chapter 10 (in collaboration with O.T. Seitzhanov, B.E. Shaimerdenov);
Yerzhan Maratovich Khakimov, M.yu.n. – chapter 5 (co-authored with O.T. Seitzhanov); chapter 6 (co-authored with O.T. Seitzhanov, S.V. Korneychuk); chapter 7; chapter 25 (co-authored with S.V. Korneychuk); chapters 34, 41; chapter 48 (co-authored with S.N. Bachurin); chapter 53;
Shaimerdenov Bolat Yerkenovich, M.yu.n., – chapter 10 (co-authored with O.T. Seitzhanov, V.V. Filin); chapter 12; articles 476-487, 507-509; chapter 36 (co-authored with O.T. Seitzhanov); chapters 37, 50, 51.
Shipp Denis Alekseevich – chapters 44-1, 46 (in collaboration with A.S. Tukiev).
Date of amendment of the act: 01.01.2020 Date of adoption of the act: 01.01.2020 Place of acceptance: 100050000000 Authority that adopted the act: 103001000000 Region of operation: 100000000000 NPA registration number assigned by the regulatory body: 5 Status of the act: new Sphere of legal relations: 029000000000 / 028000000000 / 029002000000 / 028004000000 / 029001000000 / 026000000000 / 001000000000 / 001008000000 / 030000000000 The form of the act: COMM / CODE Legal force: 1900 Language of the Act: rus
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