At present the State revenue committee of the Ministry of finance of the Republic of Kazakhstan considers a draft of the Rules on implementation of the pilot project on accounting of the certain types of goods upon their export from the Republic of Kazakhstan (the 'Pilot project')1.

The Pilot project is aimed at controlling movement of the sanctioned goods2 from Kazakhstan to Russia in order to prevent the sanction regime breach.

In view of this, in case the Kazakh exporters intend to export the sanctioned goods from Kazakhstan to Russia, they will be required to file the following documents to the Kazakh state revenue authorities (the 'SRC'):

  • application on verification of electronic invoices;
  • copies of electronic invoices on the sanctioned goods;
  • copies of declarations on the sanctioned goods.

The SRC shall verify the provided documents within 1 calendar day via examination of the following information:

  • compliance of the electronic invoices contained in the information system of electronic invoices (the 'Electronic invoices system') with the provided copies of the electronic invoices;
  • compliance of the declarations contained in the Astana-1 information system (the 'Astana-1 system') with the provided copies of the declarations;
  • compliance of the information on leftovers with the information indicated in the filed application;
  • reconciliation of the copies of the electronic invoices with the copies of the declarations for the purposes of the state of origin determination (the code of the goods origin, the code of the manufacturer state etc.).

The SRC refuses to verify the documents in one of the following cases:

  • the provided copies of the electronic invoices/declarations are incompliant with the electronic invoices/declarations contained in the Electronic invoices system/Astana-1 system;
  • the sanctioned goods are manufactured in the state which prohibits their export to Russia.

In case of such refusal, the Kazakh exporter will not be able to export the sanctioned goods from Kazakhstan to Russia.

It should be noted that in case of any changes in the electronic invoices/declarations (adjustment, annulment etc.) on the sanctioned goods, it is required to undergo the verification procedure anew.

At present it is anticipated that the Pilot project will be in effect until the end of this year.

We will keep you informed on any possible changes in this regard.

Footnotes

1 https://drive.google.com/drive/u/0/folders/1sI67lYRmMFAIfpz_Xdvez3h1_EZHNH_P

2 The list of the sanctioned goods and persons can be found at http://traderadar.kz

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.