Kazakhstan is not going to rework the core of its new Tax Code any time soon. At a government briefing on October 13, Deputy Prime Minister and National Economy Minister Serik Zhumangarin said the split between tax regimes stays as it is: businesses selling to other businesses (B2B) remain on the general regime, while those selling to consumers (B2C) can use special regimes. The rule that companies most often complain about, a ban on deducting costs paid to suppliers on the simplified declaration regime, also stays. The code took effect on January 1, and in the minister's view it needs to run for at least another year and a half before anyone can judge it.
The same day, the National Economy Ministry reported nine-month revenue figures to the government. Tax receipts to the state budget reached KZT 19.3 trillion, up KZT 3 trillion, or 18.2%, from a year earlier. VAT drove the increase, rising 37.3%: VAT on domestically produced goods grew 54.1% and VAT on imports 23.9%.
Three numbers from the briefing
The first is the payoff from the reform. At the end of last year the government expected the tax reform to bring in more than KZT 4 trillion, over KZT 2 trillion of it from VAT. Nine months in, Zhumangarin said, it has delivered KZT 3 trillion, and he expects at least KZT 3.6 trillion for the full year.
The second is the number of payers. Legal entities registered for VAT rose by about 37,000 in a year, compared with the usual 4,000 to 6,000.
The third is the backdrop. The economy grew 4.2% in nine months even though oil output fell by about 6 million tonnes, the tenge strengthened sharply and consumer lending cooled. Zhumangarin called the tax reform the economy's "only source of cash" right now.
What exactly is staying
Reporters asked about the issue entrepreneurs raise most: whether purchases from companies and sole traders on the simplified declaration will become deductible again. "No, we are not planning that," Zhumangarin said. The regime structure, he explained, is designed so that B2B businesses work under the general regime and pay VAT and other taxes, while those serving consumers have special regimes to choose from. Changing the code's main articles when it has barely started working would be, in his words, "the height of recklessness."
His answer covered the regime split and the deduction ban, not every amendment. According to a September 28 statement by Atameken, the National Chamber of Entrepreneurs, government agencies are preparing a bill to amend the Tax Code that includes tougher administration rules, such as suspending the issue of electronic invoices and suspending sales on websites and online platforms. The chamber is gathering business feedback on those provisions.
What the code says
Article 286 of the Tax Code lists non-deductible costs. Subparagraph 16 covers a taxpayer's costs of buying goods, work and services from persons applying the special tax regime based on a simplified declaration on the date the goods, work or services are received. For goods, that is the date of actual transfer to the buyer as shown in the transfer documents.
The rule sits in the corporate income tax section. The standard CIT rate under the general regime is 20% (Article 357), the VAT rate is 16% (Article 503), and mandatory VAT registration applies once turnover reaches 10,000 monthly calculation indices, or MCI (Article 99).
Article 715 sets out three special regimes. The self-employed regime is open to Kazakh citizens and kandas (ethnic Kazakh returnees), with an income cap of 300 MCI a month, zero personal income tax and social payments of 4%. The simplified declaration regime is for resident sole traders and legal entities, with an income cap of 600,000 MCI a year and a 4% rate that local councils (maslikhats) may lower or raise by up to 50%. The regime for peasant and farm households carries a 0.5% personal income tax.
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Subparagraph 16 names only the simplified declaration regime, and what counts is the supplier's regime on the day the goods or services are received. Under Article 716, the dates on which a taxpayer starts or stops applying that regime are posted on the authorized body's website no later than three working days before those dates.
Business's compromise: 8% in exchange for deductions
Atameken has pushed a workaround for some time. In November 2025, deputy chairman of the chamber's board Timur Zharkenov told BES.media about a two-tier rate: 8% for simplified-regime suppliers working with companies, which would then keep the deduction, and the base 4% for sales to individuals. At the Astana Tax Forum on August 21, 2026, the chamber repeated the proposal and said that, on instructions from Zhumangarin as head of the Project Office for implementing the code, the rule's impact on business was being analyzed and the question would return in the autumn. At a working meeting on September 28, keeping CIT deductions for B2B deals with simplified-regime suppliers was again near the top of the list.
After the October 13 answer, that proposal will not make it into the code soon. Counting the year and a half the minister mentioned from the date the code took effect, the topic could return around mid-2027 at the earliest. That is our reading of his words; no official date has been given.
A rough calculation
Suppose a Chinese-owned LLP (TOO) on the general regime is profitable for the year and pays KZT 100 million to simplified-regime sole traders for trucking, loading and repairs.
Under subparagraph 16 as it stands, the KZT 100 million is not deductible, so at a 20% rate the company pays about KZT 20 million more in CIT. The supplier pays 4%, or about KZT 4 million.
Under Atameken's scheme, the supplier would pay 8%, about KZT 8 million, or KZT 4 million more, while the buyer would deduct the KZT 100 million and save roughly KZT 20 million. Same deal, but the extra tax moves from buyer to seller and shrinks several times over. Our assessment is that the current rule pushes part of B2B trade onto the general regime and into VAT, which fits the rise in VAT payers Zhumangarin described.
The calculation ignores loss carryforwards, maslikhat rate adjustments and changes in contract prices; it only shows orders of magnitude.
Questions to ask a supplier before signing
- Which regime is the supplier on now, and could that change by the delivery date? Has a start or end date been posted on the tax authority's website?
- Does the price allow for the roughly 20% CIT difference if the cost cannot be deducted?
- Can the supplier invoice as a VAT payer on the general regime?
- Does the contract require notice of a regime change and set out how the price would be revised?
The cover image is an AI-generated illustration and is not directly related to the news.
Sources:
Official Information Source of the Prime Minister of Kazakhstan (National Economy Ministry report, English), https://primeminister.kz/en/news/kazakhstans-gdp-growth-reached-42-in-the-first-nine-months-of-the-current-year-31989
Official Information Source of the Prime Minister of Kazakhstan (Russian), https://primeminister.kz/ru/news/rost-vvp-kazahstana-po-itogam-devyati-mesyacev-tekushchego-goda-sostavil-42-31989
Bizmedia.kz, https://bizmedia.kz/2026-10-13-postupleniya-po-nds-vyrosli-na-373-zhumangarin/
Tax Code of the Republic of Kazakhstan, Adilet legal database, https://adilet.zan.kz/rus/docs/K2500000214
Tengrinews, https://tengrinews.kz/kazakhstan_news/ne-planiruem-menyat-jumangarin-nalogovyih-rejimah-biznesa-610719/
Informburo, https://informburo.kz/novosti/verx-bezrassudstva-zumangarin-otvetil-na-prosby-biznesa-izmenit-nalogovyi-rezim
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NUR.KZ, https://www.nur.kz/nurfin/fines-and-taxes/2442169-velikolepno-vedet-sebya-glava-mne-o-nalogovoy-reforme-v-kazahstane/
Kazakhstan Today, https://www.kt.kz/rus/ekonomika/ona_ne_prosto_udalas_ona_sebya_velikolepnym_obrazom_1378002099.html
Ulysmedia, https://ulysmedia.kz/news/82796-reforma-udalas-pravitelstvo-ne-planiruet-otmeniat-zapret-na-vychety-v2v/
Atameken National Chamber of Entrepreneurs (Astana Tax Forum, August 21, 2026), https://atameken.kz/news/57244-astana-tax-forum-npp-atameken-predstavila-pervye-itogi-raboty-proektnogo-ofisa-po-vnedreniyu-nalogovogo-kodeksa
Atameken National Chamber of Entrepreneurs (working meeting, September 28, 2026), https://atameken.kz/news/57443-atameken-i-biznes-obsudili-predlozheniya-po-nalogovomu-administrirovaniyu-v-ramkah-novogo-nalogovogo-kodeksa
BES.media, https://bes.media/news/biznes-massovo-zhaluetsya-na-zapret-vichetov-vihodom-mozhet-stat-dvoynaya-stavka-po-uproshyonke/
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