AGRICULTURAL COOPERATIVES: WHEN SHOULD I PAY 3%, 6%, OR 20% CPN?
Starting from January 1, 2026, Kazakhstan has differentiated corporate income tax (CIT) rates for agricultural production cooperatives (SPCs).
The main rule: The rate depends not just on the status of the cooperative or the OKED code, but on what exactly it does and where it gets its products from.
3%
Its products
6%
SEC activities
20%
Other activities
When does 3% apply?
If the cooperative is a direct producer of agricultural products.
Examples:
The SEC independently grows wheat and sells the crop.
The cooperative breeds cattle and sells the raised breeding young.
SEC produces its own milk, processes it into cheese, butter or other dairy products and sells the finished product.
Condition: the products must be produced in-house by the cooperative.
When is 6% applied?
If the SEC carries out cooperative activities provided for by the Tax Code that do not fall under the 3% rate.
Examples:
The cooperative buys the milk produced by its members, processes it and sells the finished products.
SEC harvests, stores, and sells grain grown by cooperative members.
The cooperative provides its members with zootechnical and other auxiliary services for the production of agricultural products.
The SEC sells to its members goods for the production and processing of agricultural products.
Important: products purchased from SEC members do not become products of the cooperative's own production. Therefore, the processing of such raw materials refers to the rate of 6%, not 3%.
When is 20% applied?
If the SEC receives income from other activities that do not comply with the terms of the 3% or 6% rates.
Examples:
The SEC buys milk from third-party suppliers who are not members of the cooperative, processes and sells products as part of its independent activities.
The cooperative provides commercial zootechnical services to third-party organizations.
SEC is engaged in independent trading or other activities not provided for in Article 16 of the Tax Code.
For such transactions, the rate is determined taking into account the actual nature of the activity and possible special provisions of the Tax Code.
Let's look at one example.
SEC Bereke is engaged in the production and processing of milk.
Own milk → cheese → sale
KPN 3%
Milk from SEC members → cheese → sale
KPN 6%
Milk from third-party suppliers → cheese → sale
CPN of 20% if the activity does not fall under preferential categories
What if a cooperative conducts several types of activities at once?
It is necessary to keep separate tax records for activities that are taxed at different rates.
This means that you need to separately account for the relevant income, expenses and calculate taxable income.
Three mistakes to avoid
1. Consider that any SEC is automatically entitled to a 6% rate on all income.
2. Apply 3% to milk processing only because it was purchased from cooperative members.
3. Focus solely on the OKED code, without taking into account the actual nature of the activity.
Save this post and share it with the heads of agricultural cooperatives! The correct determination of the CPI rate will help to avoid errors in tax reporting and additional charges.
Department of State Revenue for Kostanay region
Basis: Articles 16, 211, 345 and 357 of the Tax Code of the Republic of Kazakhstan dated July 18, 2025 No. 214-VIII.