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«AstyqQoima»
VIRTUAL GRAIN WAREHOUSE

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Telegram group on issues of the grain traceability system

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The information service “Virtual Grain Warehouse «AstyqQoima»” (hereinafter – IS «AstyqQoima») is intended to create a grain traceability system, which includes full accounting of its circulation (import, production, storage, processing, sale, export).

This system is being created in accordance with paragraph 1-1 of Article 68 of the Tax Code of the Republic of Kazakhstan and the Cooperation Agreement on combating illegal activities and developing fair competition in the agricultural products market, dated June 4, 2021, as part of the pilot project for simplified VAT refund to grain market participants who have joined the Memorandum on grain circulation (hereinafter – the Memorandum).

    Participants who have joined the Memorandum must adhere to the following obligations in their activities:
  • 1) prevent the use of illegal tax optimization methods;
  • 2) refrain from participating in illegal VAT refund schemes, as well as resist involvement in such schemes;
  • 3) strive to purchase agricultural products directly from farmers, processors, or commission firms, as well as from other bona fide market participants;
  • 4) exercise due diligence and integrity when selecting counterparties when purchasing agricultural products from suppliers who are not their producers;
  • 5) ensure due diligence when choosing carriers by signing contracts with transportation companies or intermediaries acting under a commission agreement on behalf of or directly from the carrier;
  • 6) make efforts to expand the number of companies that have joined the Memorandum;
  • 7) adhere to the principle of presumption of good faith of participants in the Memorandum;
  • 8) use tax clauses in contracts that provide for the disclosure of tax secrecy regarding tax gaps and mechanisms for reimbursing losses to the state budget of Kazakhstan from “tax gaps” directly caused by the taxpayer;
  • 9) inform all participants in the chain about the existence of a “tax gap” at any stage.

Access to the IS «AstyqQoima» databases is provided by the Joint Stock Company “Information and Accounting Center,” which, in accordance with the Resolution of the Government of the Republic of Kazakhstan dated August 5, 2016 No. 452, was designated as the Registrar for the provision of paid electronic services, to two categories of users:

- employees of state revenue authorities: on the basis of a written request;

- grain market participants who have joined the Memorandum: on a paid basis for servicing the client’s personal account**. To do this, it is necessary to pay the annual subscription fee in accordance with paragraph 9.2 of the Price List and sign with an EDS* an application to join the User Agreement.

* EDS – electronic digital signature issued by the National Certification Authority of Kazakhstan for legal entities.
** Clients who previously paid under the Price List for working with grain receipts are not required to make an additional payment for access to IS «AstyqQoima».

Creation of a Grain Traceability System

A full accounting of grain turnover includes tracking imports, production, storage, processing, sales, and exports. Currently, grain turnover accounting in Kazakhstan is weak and characterized by low reliability. This situation leads to problems in ensuring food security of grain.

A full accounting of grain turnover includes tracking imports, production, storage, processing, sales, and exports. Currently, grain turnover accounting in Kazakhstan is weak and characterized by low reliability. This situation leads to problems in ensuring food security of grain.

Currently, quantitative and qualitative accounting of grain turnover in Kazakhstan is based on:
1) state statistics;
2) the grain receipts registrar.

The reliability of state statistics data is constantly questioned due to distortions caused by:
1) motivation of local authorities to inflate sowing, harvesting, and yield figures;
2) preferential tax regimes;
3) linkage of the VAT refund system (for exports);
4) linkage of subsidies to fieldwork.

Grain imports mainly come from Russia and are in fact not officially recorded, since importers are not interested in paying VAT on imports and also want to benefit from preferential railway tariffs for export shipments.

Grain production accounting is based on declarative reporting forms, allowing inaccuracies due to the absence of verification procedures.

Grain storage accounting is divided between the digital accounting of the grain receipts registrar at licensed elevators with 12 million tons of storage capacity and state statistics accounting at unlicensed warehouses with a total storage capacity of about 16 million tons.

The digital accounting of the registrar is more reliable compared to statistical accounting at unlicensed warehouses, as it provides format-logical control procedures during data entry and also creates and keeps “digital traces” for subsequent verification.

Grain processing accounting is also done by state statistics and is declarative in nature.

Accounting of grain exports is based on railway carrier data and the State Revenue Committee of the Ministry of Finance of Kazakhstan and is the most reliable.

Reliability issues in accounting at each stage of grain turnover ultimately accumulate into the general problem of unreliable statistical grain turnover accounting in the country.

As a result, the Government of Kazakhstan does not have the data necessary to ensure food security.

According to preliminary estimates by the Union of Grain Producers of Kazakhstan, the shadow grain market amounts to about 9 billion tenge annually.

The introduction of grain and flour export bans and quotas in spring 2020 created many disputes regarding the justification for such restrictions. In fact, the Ministry of Agriculture of Kazakhstan cannot substantiate such decisions with precise figures.

Most market participants consider the ban unjustified and excessive. As a result, many traders failed to fulfill export contracts and were forced to return advance payments.

All market participants unanimously agree on the need to create a reliable grain accounting system that would ensure the grain market operates on civilized and predictable grounds.

It should be noted that over the past 4 years, the agro-industrial complex has made significant progress in digitalization. Digital maps of all fields have been created, every field owner is accounted for, space monitoring of sowing, vegetation, and harvesting is conducted, the turnover of electronic grain receipts issued by licensed elevators has been fully digitized, integration with railway transportation data has been implemented, electronic invoicing has been introduced, etc.

This level of digitalization makes it possible to implement a highly integrated grain traceability information system based on the principle “from field to processing/export.”

The system will include accounting of:
1) objects: fields, agricultural machinery, warehouses, processing enterprises;
2) subjects: field, warehouse, and processing plant owners, traders, and exporters;
3) processes: crop sowing, harvesting, storage, sales, utilization;
4) documents: electronic phytosanitary and veterinary (feed) certificates, technical regulation inspection acts, export declarations, shipping documents, etc.

Implementation will require improvement of the regulatory framework. The analysis showed that amendments to the legislative framework are not needed, only the adoption of regulatory acts at the level of the ministries of agriculture, trade, and finance.

The creation of a grain traceability system will allow:
1) to create conditions for the development of grain trade, including exchange trading;
2) to reduce the level of the shadow economy;
3) to increase confidence in Kazakh grain in export markets;
4) to establish a foundation for further digitalization of the agro-industrial complex in terms of implementing traceability of meat, fish, and other types of products.

Presentation Materials

GRAIN TAX TRACEABILITY SYSTEM

Video Instructions

Legal and Contractual Framework

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