The complexity of International Tax Law, including the Convention on the Avoidance of Double Taxation, and peculiarities in the taxation of non-residents raise many questions for which GRATA Law Firm specialists can provide clear answers.

We consult on issues of the permanent establishment of non-residents, tax optimisation of income of non-residents from sources, corporate structure and structure of transactions from a tax perspective, and refunds of income tax and the opening of conditional bank deposits.

  • advice on taxation of income earned by non-residents from management, consulting services, services to personnel, and application of conventions on avoidance of double taxation. Analysis of risks linked to creation of a permanent establishment  and obligations to pay VAT for a non-resident;
  • advising the world's largest food producer on taxation of royalties paid to non-residents;
  • advice to airline company on tax consequences of an aircraft  lease agreement;
  • advice to International Financial Corporation on tax aspects of a loan agreement;
  • consultations  to a leading European bank on tax issues for Eurobonds, as well as possible tax risks;
  • advice to an uranium company regarding tax treatment of interest and other payments under a loan agreement, potential tax risks associated with ‘gross-up clause;
  • advice to the European Bank for Reconstruction and Development on tax treatment of interest and other payments under a loan agreement;
  • advice to International Financial Corporation on tax treatment of remuneration payment under a loan agreement;
  • advice to the leading European aerospace company on tax issues related to services rendered to the Kazakhstan National Company for the design, installation and testing of aerospace equipment;
  • advice to major telecommunications companies on legal consequences of debt restructuring.
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16.01.2018

Kazakhstan: New user identification requirements "further regulate social relations"

It has shown a particular interest in  the  Law of 28 December 2017 No. 128-VI on Introducing Amendments and Additions to some Legislative Acts of the Republic of Kazakhstan on Information and Communication ('the Law'), which, among other amendments, requires website operators to collect identification data of website users who post comments on such websites. 

GRATA International commented on the following questions:

1- What is the background to the Law, and the Kazakh government's reason for introducing it?

2- Which types of companies will be affected by the provisions with regard to i) identifying website users ii) retaining user data? How is this likely to affect the operation of websites, and their users? 

11.01.2018

Kazakhstan has ratified the Convention on avoidance of double taxation with Ireland

On 29 December 2017 the Republic of Kazakhstan has ratified the Convention on avoidance of double taxation with Ireland[1] and the Protocol thereto (hereinafter – the ‘Convention’).


11.01.2018

Изменения в российском законодательстве в 2018 году

Команда юристов GRATA International в России подготовила обзор наиболее важных изменений в законодательстве Российской Федерации, вступающих в силу в 2018 году. 

11.01.2018

ICOs go legal in Belarus: what the Hi-Tech Park 2.0 can offer the IT industry

Belarus adopted the revolutionary legal framework for IT companies and blockchain enthusiasts. The President’s Decree on Digital Economy comes into force on March 28, 2018.

GRATA International had a presentation at the Shanghai Bar Association

On December 23, 2017 Managing Partner of GRATA International’s Uzbekistan office Bakhodir Jabborov made a presentation at the Shanghai Bar Association

20.12.2017

Special Focus - One Belt One Road China Investment

GRATA International contributed to LexisNexis Mergers & Acquisitions Law Guide 2018. Special Focus - One Belt One Road China Investment.

20.12.2017

Liberalization of business conditions in Belarus

On November 23 the President of the Republic of Belarus has signed Decree No. 7 “On the Development of Entrepreneurship”. The document significantly simplifies business activities in Belarus. Below you can find main innovations for business introduced by the document.

GRATA International attended the AmCham HR Committee meeting

On 15 December 2017, AmCham HR Committee's December Meeting took place in the office of Nobel Oil in Baku.

GRATA International attended the Azerbaijani-Georgian business forum

On 15 December 2017, the Caspian European Club and Caspian Energy Georgia with the support of the Embassy of the Republic of Azerbaijan in Georgia held the Azerbaijani-Georgian business forum and the third CEO of Lunch Tbilisi.

GRATA International attended the 23rd Azerbaijan International Telecommunications and Information Technologies Exhibition and Conference

On 5 December 2017, the 23rd Azerbaijan International Telecommunications and Information Technologies Exhibition and Conference took Place in Baku Expo Centre. The exhibition marked the beginning of High Technologies Week. The organiser of the exhibition was the Caspian Event Organisers.

GRATA International attended International Taxation Conference 2017 in India

On 7-9 December 2017, Bolormaa Volodya, Partner, and Altanzaya Gunsen, Taxation Counsel of Absolute Advocates LLP, GRATA International's associate office in Mongolia, have attended International Taxation Conference 2017 in Mumbai, India.

14.12.2017

GRATA International in Chambers Asia-Pacific 2018

GRATA International performed exceptionally well in this year’s rankings as its Azerbaijan, Kazakhstan, Kyrgyzstan, Tajikistan and Uzbekistan offices were ranked by Chambers Asia-Pacific 2018, confirming GRATA International's dominant position in Central Asia.

14.12.2017

GRATA International is a Mondaq Contributor With Most Reader Response In Russian Federation

During the Month of November 2017 GRATA International (Russian Federation) generated the most usage from Mondaq users for the  category of commercial law.

13.12.2017

GRATA International organised a practical seminar: Roadmap to Profitable Small Hydro Power Plant Development in Bishkek

On 30 November 2017 in Bishkek GRATA International organised a practical seminar: Roadmap to Profitable Small Hydro Power Plant Development, together with international engineering firm  ILF Consulting Engineers.

13.12.2017

GRATA International organised a practical seminar: Roadmap to Profitable Small Hydro Power Plant Development in Almaty

On 28 November 2017 in Almaty GRATA International organised a practical seminar:  Roadmap to Profitable Small Hydro Power Plant Development, together with international engineering firm  ILF Consulting Engineers.

11.12.2017

Stepanov and Aksuk Law Firm Associate office of GRATA International is Recognised by Право.ru-300 Ranking 2017 in 4 Nominations

On 7 December 2017, the results of the national law firms rating – ‘Право.ru-300’ were announced.

07.12.2017

Drinks reception was held at the residence of the British Ambassador to the Republic of Kazakhstan

On 6 December 2017 the drinks reception was held in Astana, Kazakhstan. 

06.12.2017

Yerzhan Yessimkhanov, partner of GRATA International, spoke at the International Conference "PPP Projects in International Context"

On 5 December 2017 the International Conference "PPP Projects in International Context" was held in Frankfurt-on-Main, Germany.

Yerzhan spoke on key questions of PPP projects implementation in Kazakhstan, particular issues of national legislation, basis PPP models in Kazakhstan, issues relating to regulation of PPP projects and key trends of development of PPP in the near future.

04.12.2017

Nurlan Kyshtobaev conducted a guest lecture on “concession agreements”

On November 28th, 2017 Nurlan Kyshtobaev, partner of GRATA International Bishkek office conducted a guest lecture on “concession agreements” and “how law firms operate”. The lecture was read to the students of International Business Law department of the American University of Central Asia (AUCA) within the course “Investment Law and Sustainable Development”. Earlier this year, GRATA International in Bishkek signed a MoU with AUCA on cooperation. 

28.11.2017

4th Downstream Caspian & Central Asia conference

4th Downstream Caspian & Central Asia conference was held in Baku, Azerbaijan on November 28.

28.11.2017

Chamber Annual Networking Reception took place in Azerbaijan

On 22 November 2017 Dubai Chamber Annual Networking Reception took place in Azerbaijan, Baku with the aim of highlighting achievements, discussing plans, and reward most active companies. 

28.11.2017

Amcham November Luncheon

On November 16, 2017, American Chamber of Commerce in Azerbaijan (AmCham Azerbaijan) organized its monthly members’ luncheon.

28.11.2017

Amcham Legal & Compliance Working Group’s November Meeting

AmCham Legal and Compliance Working Group hosted its regular meeting on November 1, 2017.

28.11.2017

Railway “Baku-Tbilisi-Kars” was opened in Azerbaijan

The opening ceremony of the Baku-Tbilisi-Kars railway (BTK) was held on October 30, 2017 in Baku.  


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Eldar Ziatdinov

Director of Tax Law Department, GRATA International (Moscow)

Moscow

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