Mass State Revenue Committee notices on tax return form 910: personal cards no longer work for revenue

The period when taking online payments on the personal cards of employees or founders looked like a convenient bit of optimisation is over for good. The State Revenue Committee of the Republic of Kazakhstan has put into operation an automated data-matching system that makes absolutely every flow of money transparent.

Today, any mismatch between declared income and the real inflows to personal cards means a desk audit notice, guaranteed.

Below we look at how the Committee's updated mechanism works, what taking money on personal cards leads to, and how an LLP can build legal payment acceptance without losing conversion.

How the control works: bank data against tax returns

The main misconception among business owners is the belief that individuals' personal bank cards are out of sight of the tax authorities.

Under the Tax Code of Kazakhstan and the financial monitoring legislation, second-tier banks pass data on citizens' transactions to the Committee against clearly defined criteria:

Risk criterion: one individual receiving mobile transfers from 100 or more different people every month for three consecutive months, totalling more than 1,020,000 tenge (255 MCI)

What happens next?

• Automatic matching: the Committee's algorithms cross-check the list of people who meet the criteria against the staff registers and founder lists of registered LLPs and sole proprietors.
• Matching against fiscal data operators and tax returns: the tax office compares the volume of credits to employees' cards with the company's official filings (forms 910.00, 300.00, 100.00) and with data from fiscal data operators.
• Issuing the notice: where discrepancies are found, the system automatically generates a desk audit notice for concealed income.

Financial and legal consequences for an LLP

If a company takes payment for its goods or services on employees' cards, the state sees deliberate tax evasion and unregistered business activity run through third parties.

That brings a whole set of hard measures:

• Additional tax assessment and late-payment interest: every amount credited to employees' cards and classed as the LLP's hidden revenue is taxed in full (corporate or individual income tax). On top of that, late-payment interest accrues for every day of delay from the moment the payment was made.
• Penalties (article 275 of the Code of Administrative Offences): concealment of taxable items by a taxpayer carries a fine of 200% of the unpaid tax. For a repeat offence within a year the fine rises to 300%.
• Frozen bank accounts: once a desk audit notice arrives, an LLP has a limited window to act on it (30 working days). If the company disagrees with the discrepancies or cannot produce supporting documents, the Committee suspends outgoing operations on all of the LLP's settlement accounts.
• Criminal liability risk: where income is concealed systematically on a large or particularly large scale, the offence moves out of the administrative field and into the criminal one (article 245 of the Criminal Code, «Evasion of tax and (or) other obligatory payments to the budget by organisations»).

The hidden losses inside the business

Beyond the direct legal risks, taking money on personal cards wrecks the company's internal economics.

• «Blind» turnover: money that never reaches the LLP's settlement account builds no official financial history. As a result banks refuse the company business loans, overdrafts and leasing, reading it as loss-making or opaque.
• The human factor and cash gaps: the money sits with a manager, not with the company. If the employee resigns, if their personal card is frozen over debts with court enforcement officers (the AIS OPRI register) or if they hit personal financial trouble, the LLP loses its operating cash.
• Load on the accounting team: trying to «close off» unofficial inflows with work completion certificates and forged receipts takes an accountant dozens of hours and leaves a permanent weak spot in any audit.

The systemic fix: official online acquiring

The only way to make an LLP completely safe and keep sales high is to move payment processes onto official online acquiring.

What does the move to professional acquiring give you?

• Direct credit to the company account: all funds arrive straight at the company's bank with the correct payment purpose code. That closes off any questions from the Committee and from financial monitoring entirely.
• Automatic fiscalisation: modern payment solutions integrate with fiscal data operators. The moment a payment succeeds, the fiscal receipt is generated and sent to the customer automatically — no manager has to punch it out by hand.
• A seamless customer experience: the client pays the familiar, safe way — through Apple Pay, Google Pay or a card from any bank in the world, in 1 click. Nobody hesitates any more over wiring a large sum to an unknown individual's name.
• Transparency for 1C and CRM: payment statuses update in your accounting system instantly. The warehouse gets the signal to pick the order right away, which removes human error and delays.

Trying to save on acquiring fees by taking money on personal cards now leads, without fail, to financial losses many times larger — in fines, frozen accounts and additional tax assessments.

Official online acquiring is a basic piece of infrastructure for a safe and scalable business in Kazakhstan.