Has the tax authority excluded expenses from your CIT deductions and VAT from your offset for transactions with an unreliable supplier, or a supplier convicted of issuing fictitious invoices? Or has it filed a lawsuit to have your transactions declared invalid? We prove that you actually received the goods, works and services, and we preserve your deductions and offsets: in objections during the audit, in a complaint to the Ministry of Finance and in court. We have been handling tax disputes since 2017 and have defended deductions on transactions worth hundreds of millions of tenge. We work throughout Kazakhstan. Fees: a fixed fee from KZT 1,500,000 plus a success fee as a percentage of the amount defended.
We examine all transaction documentation, the chain of movement of goods/services, financial flows, and actual circumstances of contract execution.
We gather direct and indirect evidence of the transaction’s reality: acceptance certificates, transport documents, correspondence, witness statements, expert opinions.
We request additional supporting documents from suppliers and partners, restore missing links in the supply chain.
We prepare a detailed analysis of the business purpose of the transaction, its impact on the company's financial indicators, and the reasonableness of commercial terms.
We build argumentation taking into account current judicial practice, clarifications from higher courts, and the specifics of your situation.
We participate in all court instances, present evidence, examine witnesses, challenge the conclusions of the tax authority and expert assessments.
We achieve recognition of transactions as valid and the right to tax deductions, establish a document flow system to minimize such risks.
Situation. The tax authority excluded from deductions and offsets the expenses and VAT on locomotive maintenance and wagon repairs worth KZT 436 million, because the suppliers were placed on the list of unreliable taxpayers after the transactions.
Task. To prove that the works were actually performed and keep the deductions and offsets.
Result. The court of first instance granted the claim in full, and the appeal court upheld the decision. Assessments of KZT 142.3 million were cancelled.
Situation. A court declared invalid the registration of a large retail company’s landlord, and the tax authority excluded the rent for retail space from CIT deductions and VAT from the offset, assessing taxes of KZT 160 million.
Task. To prove that the company actually rented and used the premises.
Result. The appeal court found all the assessments unlawful.
Situation. The tax authority considered an oil company’s transport contractors to be unscrupulous and excluded expenses from CIT deductions and VAT from the offset on transactions with them worth KZT 874 million.
Task. To confirm the reality of the transportation and keep the deductions and offsets.
Result. The Ministry of Finance fully cancelled the CIT, VAT and penalty assessments of KZT 300 million.
Not necessarily. If you actually received the goods, works or services, this can be proven and your CIT deductions and VAT offsets preserved. The earlier the evidence is gathered, the better the chances, so contact us as soon as you learn of a problem with a supplier.
Documents on the receipt and use of goods, works or services, correspondence, photos and videos, witness statements and information on how the counterparty performed the contract. Which of these are needed in your case, we determine after reviewing the materials.
Yes. In our practice, a court cancelled assessments of KZT 142.3 million in exactly this situation.
A fixed fee from KZT 1,500,000 plus a success fee as a percentage of the amount defended. We set the exact terms after reviewing the case materials.
Yes, throughout Kazakhstan. We file complaints through the eOtinish.kz portal and attend court hearings online or in person.
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