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Tax Dispute Resolution & Appeal Support

In recent years, there has been a steady trend of increasing the number of tax notifications issued to taxpayers under desk audits.

Our team has extensive experience in successfully appealing tax notifications of any complexity, both in pre-trial and judicial proceedings.When preparing complaints against notifications, we work together with our legal team, which allows us to significantly strengthen the client's position when participating in court.Our tax consultants also directly participate in court proceedings.

Situations Where We Step In:

  • A desk audit notice has been received — deadlines for compliance or appeal are already running
  • The notice is based on claims against counterparties: transactions held invalid, the supplier deregistered — and you are the one asked to pay
  • The discrepancies cited in the notice are explainable — but the tax authority will not accept explanations
  • The notice has been recognized as unfulfilled, and the company faces suspension of debit operations on accounts
  • A complaint to the higher authority did not succeed — it is time to go to court
  • Notices arrive systematically — you need a partner who will work through the flow and eliminate the root cause

Our Approach:

  • We start with deadlines: we record receipt dates and deadlines for each notice — a missed deadline destroys even a strong position;
  • We assess the merits: we unpack what stands behind desk audit discrepancies and gather evidence of the reality of operations;
  • We prepare the position with court in mind from the start: the explanation and complaint are written to become the foundation of judicial defence, not a formal reply;
  • We work as two teams in tandem: tax consultants strengthen the position with professional methodology, lawyers with procedural technique, and our consultants personally take part in court hearings;
  • We fight the root cause: if notices keep coming on the same grounds, we seek a decision that closes the issue systemically — not notice by notice.

Why Us

Tax Consultants Who Appear in Court Themselves

The usual market practice: a consultant writes an opinion, a lawyer goes to court — and the nuances of tax methodology are lost in the hearing. With us it is different: complaints are prepared jointly by the tax and legal teams, and tax consultants take part directly in court hearings. The judge hears the arguments first-hand — from a specialist who understands both the numbers and the law.

Our experience includes cases where even court decisions holding transactions invalid did not lead to additional assessments under desk audit notices, as well as amicable settlement of a dispute on recognizing a notice within court proceedings. We handle disputes at every level, including the Supreme Court of the Republic of Kazakhstan.

Before we start, we honestly assess the prospects of an appeal — and if the notice is well founded, we will say so immediately, saving you time and money.

Our Cases.
How we helped our clients
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When court decisions to invalidate transactions do not result in additional assessments
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Brief description of the case:

When a desk audit notification arrives referencing already-issued civil court decisions

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01
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16
VAT with penalties: when businesses can also claim compensation
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Brief description of the case:

Our team represented the interests of a major investor in a case reviewed by the Supreme Court of the Republic of Kazakhstan on the matter of

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01
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16
Successful court practice on VAT refunds: September 2024 results
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Brief description of the case:

In September 2024, we participated in 6 cases in first instance and appellate courts, and in all cases

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01
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16
Cancellation of additional assessments under Notification - 1.5 billion tenge
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Brief description of the case:

Comprehensive support for a client (the world's largest oil service company) during a customs audit by the territorial State Revenue Department

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01
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16
Additional assessment amount of 5.5 billion tenge excluded
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Brief description of the case:

Successfully challenged environmental inspection results regarding waste classification generated at...

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01
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16
Challenged damages for above-standard violations
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Brief description of the case:

Challenged environmental inspection results regarding dust from CHP waste, challenged damages for above-standard violations amounting to 1.2 billion tenge.

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01
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16
Peaceful settlement of dispute within court proceedings
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Brief description of the case:

Peaceful settlement of dispute within court proceedings with tax authority regarding notification recognition

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01
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16
Consulting on transfer pricing matters
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Brief description of the case:

Consulting on transfer pricing matters for transactions totaling $200 million USD.

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01
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16
Theft scheme prevented
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Brief description of the case:

Full legal support for conducting internal investigation into theft incidents at

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01
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16
Court challenge of tax authority's claim
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Brief description of the case:

Court challenge of tax authority's claim to invalidate transactions of a major trading company for procurement and sale of scrap...

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01
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16
Proved unlawfulness of tax authority demands amounting to $6 million
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Brief description of the case:

Successfully appealed tax authority demands against a major oil production company regarding historical compensation fees

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01
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16
Court decisions regarding property worth over 2.5 billion tenge overturned
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Brief description of the case:

Appeal to the Supreme Court of Kazakhstan for a foreign investor against court decisions invalidating a purchase and sale transaction

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01
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16
Customs authority claims of 156 million tenge withdrawn
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Brief description of the case:

Comprehensive audit support (consulting company personnel on audit-related matters, communications with

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01
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16
Notification for 50 million tenge cancelled
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Brief description of the case:

Prepared appeal against notification based on customs audit results and supported it at Customs Committee and State Revenue Department. As a result, cancelled

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01
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16
Additional assessments of 1.6 billion tenge cancelled
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Brief description of the case:

Company support at the Appeal Commission of the Ministry of Finance of Kazakhstan regarding appeal of customs authority actions on additional assessments

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01
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16
Customs value reassessment of 600 million KZT cancelled
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Brief description of the case:

Successful challenge of a customs reassessment of over 600 million KZT for a major retail company over the inclusion of franchise royalty payments in customs value

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When It Is Important to Reach Out

Appeal deadlines for notices are strictly limited by law, and the consequences of missing them range from an unfulfilled status to a freeze on debit operations.

  • on the day the notice is received — to build a position calmly, not to fight a fire
  • before the deadline for complying with the notice expires
  • when your explanation is rejected by the tax authority
  • immediately after a higher authority decision against you — court deadlines are already running
  • when there is a threat of suspending debit operations on accounts

Get an Initial Analysis of Your Situation

At a meeting or call, our specialist will:

1

assess whether the notice is well founded and the prospects of an appeal

2

check the deadlines: what can still be done and by which dates

3

outline a strategy: explanation, complaint to a higher authority, or court

The Key to Success

The key to success is the tandem of tax and legal teams: specialists with experience in tax authorities and the Big Four prepare the position together with lawyers and defend it in court themselves. The argumentation is not lost in handover — from the first explanation through to the Supreme Court of the Republic of Kazakhstan, the same people carry the position.

Olzhas Kassenov
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Olzhas Kassenov

Director of Tax Department

Olzhas Kassenov

Director of Tax Department

Over 20 years in Kazakhstan tax authorities, including heading a department at the Ministry of Finance. Experience at BIG 4 and holding structures. 

Specialization: tax consulting, audit appeals, pre-trial and litigation processes. LL.M Brunel University (UK).

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Yerlan Kuspanov
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Yerlan Kuspanov

Tax Department Manager

Yerlan Kuspanov

Tax Department Manager

Over 10 years of consulting experience, including 6 years at Big4. Specialization: subsoil user taxation, tax audit, audit support. Expert on non-resident and subsoil user taxation. Member of the Chamber of Tax and Legal Consultants of Kazakhstan.

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Дамира Жусупаева
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Дамира Жусупаева

Менеджер налогового департамента

Дамира Жусупаева

Менеджер налогового департамента

Дамира обладает более чем 8-летним опытом работы в консалтинге, включая 7 лет в большой четверке (Big4), специализирующихся на оказании услуг в области налогообложения

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Rustem Kakimov
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Rustem Kakimov

Senior Tax Department Consultant

Rustem Kakimov

Senior Tax Department Consultant

Specialization: international taxation, audit support, pre-trial and litigation appeals. Experience: tax consulting for industrial holdings, oil companies, subsoil users.

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Armangul Kaiyirken
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Armangul Kaiyirken

Senior Tax Department Consultant

Armangul Kaiyirken

Senior Tax Department Consultant

5 years of experience at Big4. Expertise: international taxation, restructuring, tax review and due diligence. Experience in subsoil use, retail, mining, banking sector.

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