VAT Refund in 2026: Who Can Use the Simplified Procedure

As of January 1, 2026, Kazakhstan has expanded the eligibility for applying the simplified procedure for refunding excess VAT. Previously available only to select categories of taxpayers, this mechanism can now be used by all categories of taxpayers applying the zero rate under Article 127 of the Tax Code of the Republic of Kazakhstan. The refund claim is reflected in the VAT return (Form 300.00), and the State Revenue Committee has already updated Form 300.00 and Annex 9 in the CNP ISNA system to reflect the new regulations.

This is a significant development for businesses. In essence, the legislator has made the VAT refund procedure more accessible to a broader range of companies — particularly those for whom tax recovery directly affects working capital, liquidity, and financial planning. This is especially relevant for exporters and companies engaged in zero-rated transactions.

That said, the simplified procedure is not automatically available to everyone. Under the Rules for Refunding Excess VAT Amounts, approved by Order of the Acting Minister of Finance of the Republic of Kazakhstan dated October 30, 2025, No. 649 (hereinafter — the Rules), a VAT payer may choose between the simplified procedure or a refund following a tax audit (clause 14 of the Rules). To qualify for the simplified procedure, two conditions must be met simultaneously: the absence of outstanding tax notices as of the date of filing the claim, and the existence of an excess VAT amount confirmed for refund following a tax audit covering the 12 months preceding the filing date. Additionally, the risk management system — including the tax authorities' analytical tools — continues to play a role in the confirmation process.

Pursuant to clause 15 of the Rules, a refund under the simplified procedure is made within 15 business days following the date of submission of the VAT return (Form 300.00) for the tax period in which the refund claim is reflected. The timeline runs from the date the return is filed — a critical factor to keep in mind when planning cash flow. In practice, the accuracy of the return, the quality of supporting documentation, the absence of discrepancies, and the company's readiness to promptly address any queries from the tax authority remain key considerations.

For taxpayers, 2026 presents not only a new opportunity but also a reason to revisit their approach to VAT refund documentation. Errors in transaction structure, primary documentation, zero-rate confirmation, or supply chain records can still affect the final outcome. That is why it is important to conduct a legal and tax review of the document package and assess potential risks before submitting the claim.

ERNST & PARTNERS attorneys support VAT refund projects, including preliminary document audits, preparation of legal positions, management of interactions with tax authorities, and representation of client interests in disputed cases. For businesses, this means more than simply filing a claim — it means professional, results-driven work.