On taxes and other obligatory payments to the budget (Tax Code)

Article 147. Notification of tax inspection

Footnote. Heading of Article 147 as amended by the Law of the Republic of Kazakhstan dated 24.05.2018 No. 156-VI (shall be enforced upon expiry of ten calendar days after its first official publication).

1. Tax authorities at least thirty calendar days before the start of a periodic tax audit, based on risk assessment, shall send or hand a notice of a tax audit to a taxpayer (tax agent) in the form established by the authorized body, unless otherwise established by this article.

2. A notification shall be sent or delivered to a taxpayer (tax agent) at the location indicated in the registration data.

A notification sent by registered mail with return receipt is considered to be delivered on the day of receipt of a reply from a postal or other communications organization.

3. In the absence of a taxpayer (tax agent) at the location indicated in the registration data, a periodic tax audit based on a risk assessment shall be conducted without notification.

4. A notification shall indicate the form of a tax audit, the list of issues to be checked, preliminary list of required documents, the rights and obligations of a taxpayer (tax agent) in the course of the tax audit, as well as other data necessary for conducting the tax audit.

5. The tax authority has the right to start a periodic tax audit based on risk assessment without notifying the taxpayer (tax agent) of the start of the audit in the presence of a well-reasoned risk that the taxpayer (tax agent) may conceal or destroy the documents required for the audit, related with taxation, or if there are other circumstances that make the audit impossible or prevent its full conduct.

The tax authority shall conduct a periodic tax audit based on a risk degree assessment without notifying the taxpayer (tax agent) on a written permission from a higher tax authority.

Footnote. Article 147 as amended by the Law of the Republic of Kazakhstan dated 24.05.2018 No. 156-VI (shall be enforced upon expiry of ten calendar days after its first official publication); dated 21.12.2022 No. 165-VII (shall be enforced from 01.01.2023).