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Tax Accounting Policy: The Document That Protects You During a Tax Audit

We develop tax accounting policies from scratch and update existing ones to reflect all changes in tax legislation. A properly drafted tax accounting policy ensures correct organisation of tax records and eliminates contentious issues during tax control — before they turn into additional tax assessments.

With the entry into force of the new Tax Code of the Republic of Kazakhstan, updating your tax accounting policy has become especially pressing. Operating under an outdated document creates discrepancies in tax records that the tax authority will interpret against you.

Situations Where We Step In:

  • The tax accounting policy has not been reviewed for years and does not reflect changes in tax legislation
  • The tax accounting policy needs to be aligned with the new Tax Code of the Republic of Kazakhstan
  • The company has just been established or is switching to a new tax regime — the tax accounting policy needs to be developed from scratch
  • A tax audit has been scheduled or is expected — you need to assess whether the current tax accounting policy will withstand inspectors' scrutiny
  • In a dispute with the tax authority, an issue arose that is not covered by the tax accounting policy — and that weakens the company's position
  • The business structure has changed: new activities, branches, or intragroup transactions that are not covered in the document

Our Approach:

  • We draft the tax accounting policy for your operations, not from a template: a generic document from the internet does not reflect the specifics of the company's transactions — and those gaps are exactly where inspectors build their claims;
  • We formulate contested positions deliberately: where the Tax Code allows a choice of accounting method, we lock in the option that benefits the company and is grounded in law;
  • We review the tax accounting policy through the eyes of the tax authority: our team supports tax audits and disputes and knows which policy wording becomes a defence argument — and which becomes grounds for additional assessments;
  • We align the tax accounting policy with accounting records and the company's real processes: gaps between documents and practice are a classic hook in an audit;
  • We update regularly: when legislation changes, we tell you exactly what needs to be changed — you do not have to track amendments on your own.

Why Us

We Know How Inspectors Read a Tax Accounting Policy

For most advisers, a tax accounting policy is a standard document. For us it is a defence tool: our team supports tax audits and represents taxpayers in disputes at every level, including the courts of the Republic of Kazakhstan. We have seen a well-drafted policy remove claims at the objections stage — and a template policy become the reason for additional assessments.

Our specialists have experience in tax authorities and Big Four firms: the document is prepared by people who understand both accounting methodology and the logic of tax control.

If everything in your current policy is in order, we will say so — and we will not sell a rewrite for the sake of a rewrite.

Our Cases.
How we helped our clients
01
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16
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

A tax accounting policy works only if it is adopted before the operations it governs. Changing it retroactively for an audit is too late.

  • before the start of a new tax year — so that changes apply from its beginning
  • when changes in tax legislation enter into force
  • when establishing a company or switching to another tax regime
  • before a tax audit is scheduled — not after receiving an order
  • when new activities appear or the business changes substantially

Get an Initial Analysis of Your Situation

At a meeting or call, our specialist will:

1

assess how up to date your current tax accounting policy is

2

identify gaps and wording that create risks in tax control

3

outline the scope of work: targeted updates or drafting a new document

The Key to Success

The key to success is a team that not only drafts tax accounting policies but also defends them in disputes with tax authorities: specialists with experience in tax authorities, the Big Four, and industrial holdings. Every wording in the document has a rationale 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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