Subsoil users are the separate category of taxpayers with their own tax regime different from the standard one.

As a result, tax advising of subsoil users requires specific knowledge and relevant experience which is what GRATA International possess.

We are glad to advise the subsoil users on the following:

  • advising on issues of calculation and payment of taxes and special payments of subsoil users including excess profit tax, mineral tax and bonuses;

  • advising on issues of tax stability regarding the prior tax law and its interaction with the requirements of the current tax law;
  • advising on maintenance of separate tax accounting;
  • advising on issues of taxation and tax planning of M&A transactions in subsoil area.

  • consulting an oil company to assess excess profit tax, especially in relation to issues of separating contract and non-contract activity to make changes and additions in a subsoil use contract;
  • development of a  calculating excess model for profit with contract’s peculiarities for subsoil use for an oil company;
  • analysis of tax regime under subsoil use contract, providing advice on calculation and payment of taxes and special payments of subsurface users for past tax periods;
  • prepare terms on VAT issues related to exploration operations for a major foreign subsurface users;
  • consulting subsoil users operating under Production Sharing Agreements in relation to revaluation of their fixed assets in accounting and taxation records;
  • consult on optimisation of repayment of loans on the basis of specifics of tax regime;
  • analysis and calculation of excess profit tax, commercial discovery bonus, and subscription bonus, with recommendations for optimization of tax liabilities;
  • consultation of a national subsoil company concerning deduction from total annual income of expenses suffered on payment of the export customs duty;
  • consultation of a large foreign subsoil user company concerning tax and customs obligations, and also assessment of tax risks during transactions with raw materials processing and export of processed products outside of the Customs Union territory;
  • identifying potential risks associated with the use of repealed tax legislation in connection with the current tax practice.
Name Position Contacts
Assel Ilyasova Partner, Head of Tax Law Department Inquire
Eldar Ziatdinov Director of Tax Law Department, GRATA International (Moscow), Representative in Kazan Inquire
Nurbol Kissembayev Partner, Branch Director Inquire
Nodir Yuldashev Partner, Construction, Telecommunications, Transport, Tax and Litigation Inquire
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Problems with Obtaining Refunds from the Budget of Excess VAT Accumulated During Mineral Exploration

Lately, obtaining a refund of value added tax (VAT) incurred in connection with the export of goods[1] has been a pressing issue.


Review of the Amendments made to the Tax Code and Administrative Code in 2013

On 26 December 2012 the President of the Republic of Kazakhstan signed the Law On Amendments to Some Legislative Acts of the Republic of Kazakhstan on Taxation.

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Key contacts

Assel Ilyasova

Partner, Head of Tax Law Department


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