Restrictions on deductions when working with the SNR: DGD in Pavlodar region warns about the risks of tax minimization
26.08.2026 09:23:15 158
The Department of State Revenue for the Pavlodar region reminds taxpayers applying the generally established regime (ESD) about the specifics of accounting for expenses when calculating corporate (CPN) and individual (IPN) income taxes.
Since 2026, a new restriction has been introduced: expenses for the purchase of goods, works and services from counterparties applying a special tax regime (SSR) based on a simplified declaration are not deductible.
According to the provisions of Article 286 of the Tax Code of the Republic of Kazakhstan (in particular, subparagraph 16 of paragraph 1), taxpayers in ESD do not have the right to deduct expenses for the purchase of goods, works and services from counterparties applying a special tax regime (SSR) based on a simplified declaration as of the date of receipt of such TRS.
However, despite the current legislative ban, some companies continue to attract suppliers who apply the tax regime based on a simplified declaration, increasing tax risks.
Since the beginning of 2026, more than 890 taxpayers have been registered in the Pavlodar region for ESD, who have purchased TRU from over 12 thousand suppliers for a total amount of about 20 billion tenge.
In the course of analytical monitoring, business entities have been identified that show losses in millions of turnover with suppliers in the National Accounting System and thereby minimize their tax obligations.
For example, LLP "A" applies a generally established regime, the number of employees is 1 person, in the first half of 2026, services were purchased from 7 taxpayers applying the tax code for a total turnover of 140 million tenge. Last year, for this taxpayer, 83% of all expenses were deductions from the SRR (a total of 36 suppliers applying the SRR), which resulted in a loss of 350 million tenge for the company by the end of the year.
There are also cases when taxpayers have allowed a reduction in advance payments to the CPN, while a significant part of the costs are deductions from the CPR.
Thus, with an increase in turnover of KZT 1,200 million (by 85%), LLP "B" recorded a decrease in acquisitions by KZT 700 million, including by KZT 609 million (87% of the total decrease) for suppliers using the SNR. A decrease in advance payments under the CPN was allowed by 167 million tenge.
We remind you that these categories of taxpayers are subject to increased attention from the state revenue authorities.
We also ask that taxpayers pay attention to the completeness of the calculation of advance corporate income tax payments for 2026. The State Revenue Committee has sent PUSH messages to taxpayers informing them about a decrease in advance payments with an increase in taxable income.
What is important for taxpayers to know
The norm is regulated by Article 286 of the Tax Code (Non-deductible expenses). These expenses are reflected in accounting as part of expenses, however, they do not reduce taxable income when forming tax reports (income tax returns).
The ban applies only to counterparties on simplified payment. Expenses related to transactions with payers of other tax regimes are deductible in accordance with the generally established procedure if all supporting documents are available.
The Department of Internal Affairs of the Pavlodar region urges entrepreneurs to be attentive to the execution of transactions and to correctly prepare tax reports in order to avoid violations and additional charges.
Office of desk monitoring
State Duma of the Pavlodar region
Source : https://www.gov.kz/memleket/entities/kgd-pavlodar/press/news/details/1279975?lang=ru