Have you received a notice of discrepancies following a desk audit? You have 30 business days to respond. If you do not respond, the tax authority suspends debit transactions on your bank accounts and the issuance of electronic invoices, and an unconvincing explanation may lead to a tax audit. We check whether the discrepancies are justified, prepare a detailed explanation with references to the Tax Code and supporting documents, and follow it through until the tax authority accepts it. We work throughout Kazakhstan.
Analysis of the notice and initial data.
What we supplement, what we correct, what evidence we request from third parties.
Legal position + economic justification of operations.
Submission of documents through the taxpayer's cabinet within the established timeframe and communication with state revenue authorities.
If legislation prohibits submitting explanations, we challenge the notice in court and prove the actual acquisition of goods, works, and services.
We eliminate risks, set up accounting/processes, explain to the team how to avoid risks.
Situation. A company operating under an agency model with foreign partners received a notice of overstated CIT deductions: the system compared expenses in the return with the electronic invoices received and found a discrepancy of almost 690 million tenge. Almost at the same time, a second notice arrived alleging that withholding CIT on a non-resident’s income had been understated by about 14.5 million tenge. The tax authority relied on National Bank data on payments to the foreign partner.
Task. To prove within the deadline that the discrepancies are not violations, and to prevent tax assessments, account freezes and an audit.
Result. We prepared detailed explanations for both notices with tax registers, contracts, acceptance certificates and bank statements. We broke down the expenses line by line in the return and showed why some suppliers do not issue electronic invoices:
For the second notice, we showed that the tax on royalties had been calculated and paid, while the fee for services rendered outside Kazakhstan is not subject to withholding tax and was reported in a separate column of the calculation that the system does not take into account during reconciliation. The tax authority accepted the explanations, and no violations were confirmed.
30 business days from the day following the day the notice is delivered. It is best to contact us in the first few days: collecting documents and breakdowns takes time.
The tax authority suspends debit transactions on bank accounts and the issuance of electronic invoices. In addition, a tax audit may be ordered on the discrepancies.
Yes. Some discrepancies can be corrected by filing amended returns, and an explanation can be submitted for the rest.
Such a decision can be appealed. Often the tax authority first issues a preliminary decision on an audit, and at this stage it can still be stopped. Read more on the page “Appealing a Tax Audit Order”.
From 400,000 tenge. The exact cost depends on the number of discrepancies and the volume of documents; we quote it after reviewing the notice.
Leave a request on the page or write to info@salyk.net
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