Image
Tax Audit Support: Resolving Claims Before They Become Additional Assessments

We support companies through all types of tax audits — from unscheduled inspections to audits initiated at the taxpayer's request, including VAT refund and non-resident CIT audits. From the first notification to the close of the audit, you are never left facing the inspectors alone.

Our goal is to build a constructive dialogue with the auditors and prepare a well-reasoned position on every issue raised. In most cases, this allows us to resolve claims at the discussion stage — before any additional assessments, appeals, or court proceedings.

Situations Where We Step In:

  • A preliminary decision or an order to schedule a tax audit has been received — you need to prepare before the inspectors arrive
  • A desk audit notice has arrived, and there is a risk that a thematic audit will be opened
  • The audit is already underway: document requests keep multiplying, and it is unclear what to answer and how to respond
  • An application for VAT refund or CIT on non-residents has been filed — an audit based on the application is ahead
  • Inspectors have voiced preliminary claims — a critical moment when additional assessments can still be prevented
  • The audit is wrapping up — the preliminary act must be handled properly: objections, explanations, evidence

Our Approach:

  • We step in at any stage, but we deliver the most value from the first notice: we prepare documents, staff, and the companys position before the audit begins;
  • We take communication with inspectors on ourselves: we respond to requests, brief employees before explanations, and do not let a careless wording become grounds for additional assessments;
  • We work ahead of the curve: for every potentially contested issue we prepare a reasoned position with calculations and documents — before it ends up in the act;
  • We check the lawfulness of the inspectors own actions: grounds, deadlines, procedure — procedural violations by the authority strengthen the companys position;
  • If additional assessments could not be avoided — we move seamlessly into appeal: the same team handles the dispute in the higher authority and in courts of all instances.

Why Us

The Audit Is Supported by Those Who Used to Conduct Audits Themselves

Our team includes specialists with experience in tax authorities. We know how inspectors questions are formed, which methodology is used to calculate additional assessments, and which arguments are accepted — and we use that in the taxpayers interest.

Results speak for themselves: a successful challenge of tax authority claims of $6 million for a major oil producer, amicable settlement of a dispute with the tax authority in court proceedings, and a series of won VAT refund cases. At the same time, our best results are those that never reached court: claims withdrawn at the discussion stage.

We assess risks honestly from the outset: on which issues the companys position is strong, and where additional assessments are justified — so that you make decisions based on a realistic picture.

Our Cases.
How we helped our clients
01
/
16
When court decisions to invalidate transactions do not result in additional assessments
Icon
Icon
Brief description of the case:

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

Learn more
01
/
16
VAT with penalties: when businesses can also claim compensation
Icon
Icon
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

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

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

Learn more
01
/
16
Cancellation of additional assessments under Notification - 1.5 billion tenge
Icon
Icon
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

Learn more
01
/
16
Additional assessment amount of 5.5 billion tenge excluded
Icon
Icon
Brief description of the case:

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

Learn more
01
/
16
Challenged damages for above-standard violations
Icon
Icon
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.

Learn more
01
/
16
Peaceful settlement of dispute within court proceedings
Icon
Icon
Brief description of the case:

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

Learn more
01
/
16
Consulting on transfer pricing matters
Icon
Icon
Brief description of the case:

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

Learn more
01
/
16
Theft scheme prevented
Icon
Icon
Brief description of the case:

Full legal support for conducting internal investigation into theft incidents at

Learn more
01
/
16
Court challenge of tax authority's claim
Icon
Icon
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...

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

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

Learn more
01
/
16
Court decisions regarding property worth over 2.5 billion tenge overturned
Icon
Icon
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

Learn more
01
/
16
Customs authority claims of 156 million tenge withdrawn
Icon
Icon
Brief description of the case:

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

Learn more
01
/
16
Notification for 50 million tenge cancelled
Icon
Icon
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

Learn more
01
/
16
Additional assessments of 1.6 billion tenge cancelled
Icon
Icon
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

Learn more
01
/
16
Customs value reassessment of 600 million KZT cancelled
Icon
Icon
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

Learn more

When It Is Important to Reach Out

Every stage of an audit narrows the room for manoeuvre. What is easy to remove in a dialogue with an inspector requires an appeal after the act — and a court case after the decision.

  • immediately upon receiving a notice that an audit has been scheduled
  • upon a desk audit notice — before a thematic audit is opened
  • before filing a VAT refund application — to prepare for the audit in advance
  • at the first signs of claims from inspectors
  • before signing the audit act — at the stage of preparing objections

Get an Initial Analysis of Your Situation

At a meeting or call, our specialist will:

1

assess the grounds and subject of the audit and identify risk areas for your company

2

review the lawfulness of the inspectors actions and demands

3

outline a support strategy: documents, communication, argumentation on contested issues

The Key to Success

The key to success is experts who have stood on both sides of an audit: specialists with experience in tax authorities, the Big Four, and industrial holdings, who take disputes through to victory at every level, including the Supreme Court of the Republic of Kazakhstan. Inspectors speak with equals — and that changes the course of the audit.

Olzhas Kassenov
Learn more
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).

Learn more
Yerlan Kuspanov
Learn more
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.

Learn more
Дамира Жусупаева
Learn more
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

Learn more
Rustem Kakimov
Learn more
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.

Learn more
Armangul Kaiyirken
Learn more
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.

Learn more
Consultation
Need our help?
Write to us, we'll get in touch.

Fill out the form and we'll contact you!

Our Partners
Logo
Logo
Logo
Logo
Logo
Logo
Logo
Logo