Fortune Partners at Minex Forum 2026
At the strategic session "Taxes, Royalties, Contracts: Rethinking the Economics of Mining", Dana Tokmurzina, General Director of Fortune Partners, joined the panel as a speaker and shared her expertise on tax matters in the mining sector.
The discussion covered issues that mining and metals companies face in daily practice — from VAT refunds to calculating relief for newly developed deposits.
Key topics
VAT refunds. The situation improved in 2026, but questions remain over whether budgetary funds are sufficient to meet refund claims. For an export-oriented sector, this has a direct effect on working capital.
Royalties and dividends. Tax authorities trace the ultimate recipient of income for the purposes of applying tax treaties. For management services, it is the economic substance of the transaction that is examined, not merely its documentary form.
Currency regulation in cross-border transactions. Penalties under the Code of Administrative Offences raise numerous questions, as practice has shifted — the approaches of the National Bank and the State Revenue Committee diverge.
Transfer pricing. The number of cases in the mining and metals sector has grown over 2025 and 2026.
Waste disposal and treatment. Additional assessments arising from these operations remain a significant area of risk for the industry.
Mineral extraction tax relief. The zero rate for new deposits has raised a practical question for companies: how should the calculation actually be performed?
The mining sector is one of Fortune Partners' core areas of specialisation. We would be glad to discuss current tax issues in mining and metals and to assess the risks of a particular structure.
