INTENSIVE RECORDINGS · 2026 SEPTEMBER STREAM

TAX SECURITY: Risk mitigation strategies and dispute resolution practices

Simply responding to notifications doesn’t work. Full recording of the intensive on the current Tax Code: how to protect your business by applying APPC, lawful tax structuring, and current judicial practice.

5 modules · 8 hours of video · PDF presentations · Lifetime access See the program below ↓

GET ACCESS TO THE RECORDINGS
Gabitzhan Kudaibergen

FOR WHOM ARE THESE RECORDS

Business owners and CEOs

Business owners and CEOs

Building a secure business architecture. You will learn how to legally apply tax preferences, properly structure transactions, and where legitimate optimization ends and illegal evasion begins.

To accountants and financial directors

To accountants and financial directors

Stop just sending generic replies to notifications! You will learn how to competently achieve the “Completed” status with full closure of the issue, avoiding blockages with the IS ESF and bank accounts.

Corporate lawyers

Corporate lawyers

Learn from the experience of your senior colleagues and apply it in your practice! Secrets of judicial practice under the APPK. You will learn why it is sometimes more advantageous to remain silent on a preliminary act and how to have inspections cancelled due to procedural errors by government agencies.

WHAT IS INCLUDED IN THE RECORD

This is not a "reading of the Tax Code." This is an analysis of the most complex judicial practice and ready–made legal tools that are working right now - records that can be reviewed at any time.

  • Video recordings of all 5 modules

    Full lecture recordings for the September 2026 cohort. Watch the modules in any order, from a computer or phone, pause and return to the desired topic before the quiz or response to the notification.

  • In-depth analysis of judicial practice

    Current cases of the Supreme Court of the Republic of Kazakhstan and the Court of Cassation in administrative cases. You will understand the judges’ logic and learn how to effectively protect business interests.

  • Ready‑made algorithms and strategies (Roadmap)

    Presentations with step‑by‑step action algorithms - from a competent response to a notification to applying the “5 to 1” rule when proving the reality of transactions in court.

  • Legal tax structuring

    Working tools for 2026: optimal choice of tax regime, application of transaction forms taking into account the specifics of tax accounting, lawful use of AIFC preferences, and much more.

Program: Maximum practice

01

DESK CONTROL: how to stop being afraid of notifications

Why have the old response methods stopped working? We define the powers of district administrations to conduct tax audits. Proper response to prevent audits and account blockages.

Analysis of practice: The cancellation of the unlawful demand by the UGD for the revaluation of buildings, which was issued in the form of a regular letter without any risk assessment, as well as an overview of other examples.
Result: You will stop panicking when you see letters from the tax authorities and will receive a clear checklist of actions to effectively comply with the notices.
02

DUE DILIGENCE AND TRANSACTION PROTECTION

What should you do if the counterparty has been removed from VAT registration or its registration has been revoked? How to preserve your deductions and prove that the transaction was real.

Analysis of practice: Maintaining the right to deduct expenses related to the rental and purchase of railway tank cars by a large logistics company. The use of witness testimony, circumstantial evidence, digital footprint, etc.
Result: The skill of collecting 100% of the evidence base to protect the company's assets in court.
03

TAX AUDITS: the procedure, the inner workings, and life hacks

The powers of inspectors under the new rules. Why lawyers sometimes recommend refusing to file objections to the preliminary act (protection under Article 129 of the APPC).

Analysis of practice: Challenging orders to conduct inspections. Cancellation of acts due to unlawful expansion of the scope of control after the taxpayer has been heard.
Result: You will learn to identify procedural errors made by inspectors and to effectively apply the APPK.
04

APPEALING THE RESULTS OF TAX AUDITS: reviews and recommendations

Where is it more effective to argue: why it’s better to resolve accounting issues with the Ministry of Finance, and legal issues in court. Applying the “5 to 1” rule against the tax authorities’ arguments.

Analysis of practice: A detailed analysis of the high‑profile case of LLP “Bogatyr Komir” in the field of international taxation, the principal purpose test (PPT) and the FPD concept. A case study of a major oil trader in the context of saving deductions.
Result: Developing a winning procedural strategy and understanding the logic behind the work of the appellate commission of the Ministry of Finance of the Republic of Kazakhstan and judges.
05

TAX OPTIMIZATION UNDER THE NEW CODE

Why are old tools so toxic? The boundaries of what is permissible: where does legitimate optimization end and illegal splitting begin? What benefits have been retained in the Tax Code? Why are people increasingly turning to the jurisdiction of the AIFC?

Elegant solutions: Optimal choice of tax regime. Contract with a foreign general contractor without incurring “input” VAT through a joint venture agreement. Correct application of OKED codes to maintain the simplified tax regime based on a simplified declaration.
Result: You will be able to structure your business and transactions in a way that allows you to legally take advantage of tax preferences.
Gabitzhan Kudaibergen

Gabitzhan Kudaibergen

MBA, lawyer, tax consultant, partner at GK and Partners

  • 18 years of experience in the tax authority system and international law firms.
  • The law firm is recognized in the global ranking The Legal 500.
  • Co‑founder of the Kazakhstan Association of Tax Consultants.
  • The cancellation of tax charges amounting to 1.4 billion and 1.6 billion tenge for large businesses and the quasi‑public sector.

PARTICIPANT REVIEWS

Видеоотзыв
Видеоотзыв
Видеоотзыв
Видеоотзыв
Видеоотзыв
Видеоотзыв

COST OF ACCESS TO RECORDINGS

The "Individual" tariff

99 000 ₸

For professionals who pay for their own participation.
Included: video recordings of all 5 modules, presentations and study guides, lifetime access, and a fiscal receipt.

The "Legal entity" tariff

149 000 ₸

For participants whose training is funded by the employer.
Included: video recordings of all 5 modules, presentations and study guides, lifetime access, and a full package of closing documents for accounting purposes (electronic acts of work performed and electronic VAT invoices – the lecturer operates under the General Tax Regime).

Please send me the payment details.