Memo No. 23 dated June 11, 2026

"I approve" Supervisor State Revenue Department for Kostanay Oblast ___________________ S. Uzakbaev June____, 2026 ANALYTICAL REPORT In pursuance of the order of the head of the Department of State Revenues for Kostanay Region (hereinafter referred to as the Department) dated March 20, 2026, No. 150 “On the creation of a working group to conduct an internal analysis of corruption risks”, the Department conducted an internal analysis of corruption risks in accordance with the approved schedule for conducting an internal analysis of corruption risks. The working group includes: Head of the working group Sarkitbaev Anuar Azatovich , Deputy Head of the Department of State Revenues for Kostanay Region (hereinafter referred to as the Department); Working group members: Zhursinalin Arman Moldagazyevich , Deputy Head of the Department; Kapbasova Gulsum Mubarakovna , Head of the Human Resources Department; Basyrova Zhasmine Ermekovna , Head of the Legal Department of the Department; Kuzbaeva Makhabbat Shaymukhamedovna , Head of the Department for Debt Management; Yeshanov Askar Nurmagambetovich , Head of the Department for Work with Insolvent Debtors; Menzaripov Kairzhan Zhaksylykovich , Head of the Audit Department; Esmukhanov Shynkushan Bagytzhanovich , Head of the Department of Desk Monitoring; Galymov Saken Zhumabekovich , head of the VAT Administration Department within the EAEU Department; Syzdykov Ermukhan Kabylkhanovich , Head of the Department of Indirect Tax Administration; Seitov Valikhan Kazmagambetovich , Head of the Department Customs Control Department; Zhumabay Shynar Zhumabayevna , Head of the Department of Non-Production Payments; Akhmetova Gulya Sainovna , Head of the State Department services of the Department; Spabekov Kasym Zhumakhanovich , head of the customs post "Kostanay-customs clearance center" of the Department. Mustafina Aizhan Anasovna , Head of the Organizational and Financial Management of the Department; Isenov Baurzhan Bakhytzhanovich , Head of the Information Technology Department; Bekmukhamedova Zarina Serimzhanovna , Head of the Department of Explanatory Work and Contact Center of the Department. GENERAL PROVISIONS 1.1 Objectives and tasks of the analysis The purpose of the analysis is to prevent and eliminate corruption in the activities of departments. The objective of internal analysis of corruption risks is to identify conditions that contribute to the commission of corruption offenses, as well as their elimination. 1.2 Sources of information used during the analysis The sources of information for conducting an internal analysis of corruption risks are the following regulatory legal acts: “Tax Code” of the Republic of Kazakhstan dated July 18, 2025 No. 214-VIII ZRK, Rules for the provision of public services, approved by order of the Acting Minister of Finance dated July 10, 2020 No. 665 "On approval of the Rules for the provision of public services, state revenue authorities of the Republic of Kazakhstan", the Code of the Republic of Kazakhstan "On customs regulation in the Republic of Kazakhstan" dated December 26, 2017 No. 123-VI ZRK,The Code of the Republic of Kazakhstan "On Administrative Offenses" dated July 5, 2014 No. 235-V ZRK, the Rules for the application of the risk management system based on criteria that are not confidential information approved by the Order of the Minister of Finance of the Republic of Kazakhstan dated February 20, 2018 No. 252, the Order of the First Deputy Prime Minister of the Republic of Kazakhstan - Minister of Finance of the Republic of Kazakhstan dated December 26, 2019 No. 1424, the Rules for posting on the Internet resource of the Ministry of Finance of the Republic of Kazakhstan a list of persons entitled to carry out the activities of an administrator, appointment and removal of rehabilitation and bankruptcy managers, approved by the Order of the First Deputy Prime Minister of the Republic of Kazakhstan MF RK dated April 1, 2020 No. 343 (hereinafter referred to as the Rules). DESCRIPTIVE PART Personnel management, including identification of positions subject to corruption risks. List of positions exposed to corruption risks: - Category CR-1, head of a territorial subdivision's department. The risk of corruption stems from the fact that the head of a territorial subdivision's department directly interacts with business entities and is empowered to make independent decisions regarding individual entrepreneurs. - Category C-O-3, Head of the Desk department. The risk of corruption stems from the fact that the head of the department of the relevant division makes decisions and provides a legal assessment of the results of the analysis conducted by employees before sending assignments and instructions to regional divisions. In order to eliminate the above risks, it is recommended to consider the issue of rotation of heads of departments of category CR-1, C-O-3. 2. Intentional delay of a tax audit by an official under the pretext of a change of location. The taxpayer changes his/her location during a tax audit. These circumstances lead to a delay in the audit and allow the taxpayer to avoid completing audit activities by changing his/her location. Recommendation: Amend the Tax Code of the Republic of Kazakhstan to provide for: Restrict the ability to change location taxpayer for the period of the tax audit; To regulate inter-territorial interaction of state revenue authorities , ensuring automatic transfer of verification materials when changing location; Security measures evasion of participation in the audit (e.g. suspension of operations, restriction of registration actions, blocking of electronic invoices). 3. The limited timeframe and the dependence of the start of the audit on the fact of delivery create conditions for protracted procedures and a selective approach, which can be used to evade control or create advantages for individual taxpayers. The established three-day period for serving a tax audit order is insufficient, as the taxpayer may be absent from their location (including for work-related reasons), and technical failures are also possible when registering the order in information systems. This complicates the timely commencement of the audit and compliance with procedural deadlines. This can lead to the expiration of the statute of limitations due to the revalidation of the order, as a result of the expiration of the service deadline. Recommendation: Extend the deadline for delivery of the order, taking into account the absence of the taxpayer and possible technical delays, while considering the delivery to have taken place after registration with the OCLSaSA. Corruption risk of unjustified return of the amount of paid registration fee. In accordance with paragraph 1 of Article 614 of the Tax Code, the amounts of fees are paid at the location of the fee payer before submitting documents to the authorized government agency or before receiving permits. In turn, in accordance with paragraph 5 of Article 612 of the Tax Code, authorized state bodies quarterly, no later than the 20th day of the month following the reporting quarter, submit to the tax authority location of its location (until the transfer is fully automated) information about fee payers and taxable items. In this regard, when obtaining permits from the authorized body of one region (for example, registering a vehicle with the authorized body of Almaty), the payers whose location is in the regions of Kostanay region, the fee is paid to the budget of Kostanay region. At the same time, the authorized body for the city of Almaty provides information about fee payers only to the State Revenue Department of Almaty. If the fee payer applies to the tax authorities of the Kostanay region for a refund of the fee amount, the tax authorities will refund the fee, since this taxpayer is not reflected in the information of the authorized bodies of the Kostanay region. Recommendation: Amend paragraph 1 of Article 614 of the Tax Code to require that the fee be paid at the location of the authorized body. Head of the working group Sarkitbaev A.A. Working group members: Deputy Head of the Department Zhursinalin A.M. _________________ Head of Human Resources Kapbasova G.M ._________________ Acting Head of the Legal Department Basyrova Zh.E .________________ Head of the Debt Management Department Kuzbaeva M.Sh. _________________ Head of the Department for Work with Insolvent Debtors Eshchanov A. N . __________________ Head of the Audit Department Menzaripov K. Zh ._________________ Head of the Office of Desk Monitoring Esmukhanov Sh.B ._______________ Head of the VAT Administration Department within the EAEU Galymov S.Zh ._______________ Head of the Indirect Tax Administration Department Syzdykov E. K ._________________ Head of the Customs Control Department Seitov V.K .____________________ Head of the Non-Production Payments Department Zhumabay Sh. Zh .___________________________ Head of the Department of Public Services Akhmetova G. S . ____________________ Head of the customs post "Kostanay-Customs Clearance Center" Spabekov K.Zh . ____________________ Head of the Organizational and Financial Department Mustafina A. A ._______________ Head of Information Technology Department Isenov B. B. ___________________ Head of the Department of Explanatory Work and Contact Center Bekmukhamedova Z. S ._______________

Appendix 5 to the Methodological Recommendations on Conducting Internal Analysis of Corruption Risks Approved by Head of the State Revenue Department for Kostanay Region ______________ S. Uzakbayev “____” June 2026 Action Plan for Eliminating the Causes and Conditions Contributing to the Commission of Corruption Offenses Identified as a Result of the Internal Analysis of Corruption Risks in the State Revenue Department for Kostanay Region No . Description of Corruption Risk Recommendations for Elimination Completion Form Position of the Authorized State Body (if recommendations are sent to another state body) Implementation Period 1 Deliberate delay of a tax audit by an official under the pretext of a change in the taxpayer's location. Introduce amendments to the Tax Code of the Republic of Kazakhstan providing for: 1) Restricting the possibility of changing the taxpayer's location during the period of a tax audit; 2) Regulating inter-territorial interaction between state revenue authorities by ensuring automatic transfer of audit materials when the taxpayer changes location; 3) Measures to prevent avoidance of participation in the audit (e.g., suspension of transactions, restrictions on registration actions, blocking of Electronic Invoices (ESF)). Letter to the SRC of the Ministry of Finance of the Republic of Kazakhstan. Amendments to regulatory legal acts. The State Revenue Department for Kostanay Region sent request No. DGD-UA-1-07/36913-VN dated April 28, 2026 to the State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan. According to the response of the SRC No. KGD-15-2-21/12321-VN dated May 22, 2026, the issue is being considered within the framework of adopting a regulatory legal act. 2027 2 The limited period for service of an order and the dependence of the audit commencement on the fact of its delivery create conditions for delaying procedures and selective application, which may be used to evade control or provide advantages to certain taxpayers. Increase the period for serving the audit order, taking into account the taxpayer’s absence and possible technical delays, while considering the order as duly served upon its registration in the Unified Registration System. Letter to the SRC of the Ministry of Finance of the Republic of Kazakhstan. Amendments to regulatory legal acts. The State Revenue Department for Kostanay Region sent request No. DGD-UA-1-07/36913-VN dated April 28, 2026 to the State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan. According to the response of the SRC No. KGD-15-2-21/12321-VN dated May 22, 2026, the issue is being considered within the framework of amendments and additions to the Tax Code. 2027 3 Corruption risk related to the unjustified refund of the paid registration fee. Amend Paragraph 1 of Article 614 of the Tax Code to provide that the fee shall be paid at the location of the authorized body. Letter to the SRC of the Ministry of Finance of the Republic of Kazakhstan. Amendments to regulatory legal acts. The State Revenue Department for Kostanay Region sent request No. DGD-UNP-1-4/37105-VN dated April 29, 2026 to the State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan regarding amendments to Paragraph 1 of Article 614 of the Tax Code. 2027

Execution of the plan and dynamics of tax revenue for the 1st quarter of 2026: GB – execution by 120% (131.8 billion tenge), rate of 122.4% (+24.1 billion tenge); RB – execution by 129.9% (72.4billion tenge), the rate of 155.7% (+25.9 billion tenge); MB – execution by 109.8% (59.4 billion tenge), the rate of 97.1% (-1.8 billion tenge).

EXTRACT FROM MINUTES NO. 20/1. meetings of the Competition Commission of the Department of State Revenues in Kostanay region of the State Revenues Committee of the Ministry of Finance of the Republic of Kazakhstan to hold an internal competition for filling vacant administrative state posts of corps "B." Kostanay June 9, 2026 According to the Rules for holding an internal competition for holding an administrative state position of corps "B," approved by order of the Chairman of the Agency for Civil Service Affairs on December 8, 2025 No. 196 (hereinafter referred to as the Rules), the competition commission DECIDED: Consider the internal competition for the vacant administrative state position of the chief specialist of the Department for Work with Debts of the Department of State Revenues in the Kostanay region of the State Revenue Department of the Ministry of Finance of the Republic of Kazakhstan, category S-O-5 failed due to the absence of candidates who received a positive opinion from the competition commission.