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Tax Burden Optimisation: Legitimate Mechanisms That Stand Up to Tax Scrutiny

We analyse a company's financial and business operations and identify lawful ways to reduce the tax burden: tax exemptions, incentives, special tax regimes, and restructuring of business processes and transactions.

What sets us apart is years of defending taxpayers in disputes with tax authorities — including before the Supreme Court of Kazakhstan. We know what tax authorities look for during audits, and we recommend only those solutions that will withstand both an audit and a dispute.

Situations Where We Step In:

  • The tax burden is growing, and management wants to know whether all lawful ways to reduce it have been used
  • A major deal is planned — the tax burden of the asset needs to be reviewed (due diligence). There may be risks of acquiring hidden debts
  • The business operates as it historically developed, and the structure has never been reviewed from a tax perspective
  • The company may qualify for incentives or special regimes, but it is unclear whether they apply and how to switch without risks
  • A group of companies grew spontaneously — intragroup transactions create tax risks and unnecessary burden
  • Previously implemented optimization raises doubts — its sustainability needs to be assessed before the tax authority does so

Our Approach:

  • We start with diagnostics: we analyze financial and economic activity, group structure, and key transactions to identify where there is lawful potential to reduce the burden;
  • We assess every solution through the eyes of the tax authority and the court: we know the practice of recharacterizing transactions and holding them invalid because we handle such disputes ourselves;
  • We work strictly within the legal framework: incentives, preferences, tax regimes, contractual and corporate structures — without aggressive schemes that turn into additional assessments with penalties and fines;
  • We calculate tax consequences comprehensively — including transfer pricing on intragroup and cross-border transactions;
  • We support implementation: from the restructuring plan to documentary formalization, so that every decision has a business purpose and an evidentiary base.

Why Us

We See Optimization from the Side That Audits It

Most advisers give recommendations on tax optimization. We go further: we support clients and protect their interests in tax disputes at every level, including the courts of the Republic of Kazakhstan. That is why every solution we propose is built from the outset around how the tax authority will review it and how a court will assess it.

Our specialists have experience in tax authorities, industrial holdings, Big Four firms, and courts. Among the results are transfer pricing advice on transactions of $200 million and a successful challenge of tax authority claims of $6 million.

We say honestly that over-optimization always brings major risks — and we do not propose solutions the client would have to pay for in an audit.

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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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

Optimization works for future periods, so it is important to reach out:

  • at the planning stage of a deal, investment, or new line of business — before documents are signed
  • during reorganization, group growth, or investor entry
  • before switching to a new tax regime or applying an incentive
  • when preparing for a new financial year — so that changes take effect from its start
  • when there are doubts about the sustainability of the current structure — before a tax audit, not during it

Get an Initial Analysis of Your Situation

At a meeting or call, our specialist will:

1

assess the structure of your activity and identify areas of potential burden reduction

2

identify tax risks in the current structure and previously implemented solutions

3

outline a plan: applicable mechanisms, restructuring stages, required documents

The Key to Success

The key to success is experts who have stood on both sides of a tax dispute: specialists with experience in tax authorities, the Big Four, and industrial holdings, who defend taxpayers in court. We propose only those solutions we are ready to stand by.

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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