The Department of State Revenues for Pavlodar region has uncovered cases of artificial understatement of the taxable base by companies operating under the generally established regime (GER). Businesses continue to engage suppliers on the special tax regime (STR), despite the legislative ban that has come into force... reports the website infohub.kz.
According to Article 286 of the Tax Code of the Republic of Kazakhstan, starting from 2026, taxpayers on the GER are no longer entitled to deduct expenses on the purchase of goods, works, and services from counterparties applying the STR based on a simplified declaration. These costs are reflected in accounting, but when preparing tax reports for corporate (CIT) and individual (IIT) income taxes, they do not reduce taxable income.
The department clarifies that the ban applies exclusively to transactions with counterparties on the simplified regime. Expenses on transactions with payers of other tax regimes are deductible in the standard manner, provided supporting documents are available.
Analytical monitoring has established that business entities generate artificial losses with million-dollar turnovers. Since the beginning of 2026, 890 taxpayers on the GER in Pavlodar region have been recorded as having purchased services from more than 12,000 suppliers on the STR for 20 billion tenge.
Camera control has identified specific optimization schemes. An LLP with one employee purchased services from seven STR payers for 140 million tenge in the first half of 2026. Last year, such deductions accounted for 83% of all company expenses (involving 36 suppliers), leading to an artificial loss of 350 million tenge.
Another LLP, with a turnover increase of 1.2 billion tenge (an 85% growth), reported a decrease in the volume of purchases by 700 million tenge. The main share of the decrease—609 million tenge, or 87%—was attributed to suppliers on the STR. Simultaneously, the company unjustifiably reduced advance payments for CIT by 167 million tenge.
The DSD warns that enterprises practicing such tax minimization are under control. The State Revenue Committee has already begun sending targeted push messages to businesses informing them of the inadmissibility of reducing advance payments when taxable income actually grows. Tax authorities urge correct reporting to avoid large additional assessments.
The new Tax Code of the Republic of Kazakhstan, which came into force in 2026, aims to eliminate systemic imbalances between different tax regimes and combat the shadow economy. One of the key goals of the reform is to close loopholes for artificial business fragmentation and illegal tax optimization, where large companies on the GER transferred profits to affiliated individual entrepreneurs with minimal tax rates.