Have you received a notice of tax audit results assessing taxes, penalties and fines? We appeal it to the higher tax authority, the Ministry of Finance and the courts. We have been handling tax disputes since 2017, and our cases include assessments of hundreds of millions of tenge that were cancelled. We work throughout Kazakhstan. Fees: a fixed fee from KZT 1,500,000 plus a success fee as a percentage of the amount cancelled.
We thoroughly examine the inspection act, the tax authority's decision, all documentation, and identify procedural and substantive violations.
We determine real chances of success, calculate possible reduction of assessment amounts, and choose the optimal defense strategy.
We prepare a reasoned appellate complaint to the Ministry of Finance of the Republic of Kazakhstan with a complete set of supporting documents.
If pre-trial appeal does not bring results, we prepare a claim statement taking into account all arguments and current judicial practice.
When necessary, we initiate independent expert examinations, request documents from third parties, and involve witnesses.
We participate in the complaint review at the tax authority and in all court instances, defend your position, and challenge the opponent's arguments.
We achieve full or partial cancellation of assessments, analyze the reasons for claims, and establish a system for preventing tax risks.
Situation. Following a comprehensive audit, the tax authority excluded from deductions the cost of cars stolen by a dealer’s employee and assessed CIT of KZT 750 million.
Task. To have the assessments cancelled.
Result. The Ministry of Finance upheld the company’s complaint on this item in full.
Situation. The tax authority excluded rolling stock repair costs from deductions, citing the fact that the counterparties were later placed on the list of unreliable taxpayers, and assessed CIT and VAT.
Task. To prove the reality of the transactions and keep the deductions.
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. The tax authority assessed CIT and penalties of KZT 1.4 billion, challenging the exemption of Eurobond interest and the deductions for a subsidiary’s services.
Task. To have the assessments cancelled on the key issues.
Result. The Ministry of Finance supported the client’s position on the key issues, and part of the assessments was cancelled.
A complaint to the Ministry of Finance is filed within 30 business days from the date the notice is delivered. The Ministry of Finance’s decision can be appealed in court within one month from the date it is delivered. The deadlines have nuances, so contact us as soon as you receive the notice, or better still at the stage of the preliminary audit report.
As a rule, first to the Ministry of Finance, and its decision can then be appealed in court. The procedure depends on the nature of the dispute; we determine it after reviewing the audit materials.
Yes. You can appeal only the assessments you disagree with.
A fixed fee from KZT 1,500,000 plus a success fee as a percentage of the amount cancelled. We set the exact terms after reviewing the audit materials.
Yes, throughout Kazakhstan. We file complaints through the eOtinish.kz portal and attend court hearings online or in person.
Leave a request on the page or write to info@salyk.net
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