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LETTER OF THE TAX COMMITTEE OF THE MINISTRY OF FINANCE OF THE REPUBLIC OF KAZAKHSTAN

No. HK-21-28/12127

Association of taxpayers of Kazakhstan

Almaty, Ulitsa Auezova, 84, office 311

The Tax Committee of the Ministry of Finance of the Republic of Kazakhstan, having considered within competence your letter of October 1, 2010 No. 645-10/10, reports the following.

According to Item 1 of article 100 of the Code of the Republic of Kazakhstan of 10.12.2008. "About taxes and other obligatory payments in the budget" (further - the Tax code), expenses of taxpayers in connection with implementation of the activities directed to income acquisition are deductible in case of determination of the taxable income, except for the expenses which are not deductible according to the Tax code.

By Item 3 of the above-stated Article it is determined that deductions are made by the taxpayer in the presence of the documents confirming the expenses connected with its activities directed to income acquisition. These expenses are deductible in that tax period in which they were actually made, except for of the deferred expenses determined according to International Financial Reporting Standards and requirements of the legislation of the Republic of Kazakhstan about financial accounting and the financial reporting.

Deferred expenses are deductible in that tax period to which they belong.

According to Item 2 of article 56 of the Tax Code tax accounting is based on accounting data. The procedure for maintaining accounting documentation is established by the legislation of the Republic of Kazakhstan on financial accounting and the financial reporting.

In turn, Item 1 of article 7 of the Law of the Republic of Kazakhstan of February 27, 2007 "About financial accounting and the financial reporting" (further - the Law on financial accounting) provides that accounting documentation includes source documents, bookkeeping registers, the financial reporting and accounting policy.

Accounting entries are made based on source documents.

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