Contents
  1. What counts as incorrect work
  2. Risk 1: reclassification as employment
  3. Risk 2: return of tax-agent duties
  4. Risk 3: expenses rejected for deduction
  5. Risk 4: bank and AML controls
  6. How to set the process up correctly

1. What counts as incorrect work

Incorrect work means paying contractors while bypassing the rules: without a contract, without an e-Salyq receipt, without checking the self-employed status, in cash or by card transfer with no paperwork. It looks simpler and cheaper at first, but the risks fall on the client company.

2. Risk 1: reclassification as employment

If a contractor in fact works as a staff employee, the relationship may be recognised as employment. From 8 June 2026, Article 26 of the Labour Code directly bans disguising employment as a GPH contract: a contract with even one sign of employment (from Article 27) is recognised as employment by operation of law. This leads to an administrative fine and retroactive assessment of taxes and social payments for the whole period. More in the article on the GPH ban from 8 June 2026.

3. Risk 2: return of tax-agent duties

When working with the self-employed under the special tax regime, the company is not a tax agent: the contractor pays taxes themselves, and the closing document is the e-Salyq Business receipt. But this only works with a confirmed active status of the contractor. If there is no status (or it is not confirmed), the tax-agent duties may return to the company — meaning withholding of personal income tax and contributions falls on you.

4. Risk 3: expenses rejected for deduction

Without supporting documents (a contract, an act of work performed, an e-Salyq receipt) the payment cannot be properly deducted for corporate income tax — the company effectively overpays tax. More in the article on CIT deductions.

5. Risk 4: bank and AML controls

Regular "business-like" payments in cash or to personal cards without paperwork attract the attention of banks and anti-money-laundering (AML) controls. This can result in source-of-funds inquiries and suspension of transactions — for both the company and the contractor.

6. How to set the process up correctly

  1. Sign a contract for a result (not a process) — without a schedule or subordination.
  2. Check the contractor's active self-employed status and activity type.
  3. Obtain an e-Salyq Business receipt for every payment and draw up an act of work performed.

Official sources: Labour Code of Kazakhstan (adilet.zan.kz), Tax Code of Kazakhstan — special tax regime for the self-employed (Law No. 214-VIII of 18 July 2025), clarifications and services of the State Revenue Committee (kgd.gov.kz), tax help on egov.kz. This material is not legal advice.