GRATA Law Firm: Experience

Tax disputes

Protecting our Subsoil User-Client’s interests in a large scale tax dispute, where the result was the cancellation of assessed taxes, fines and penalties of a sum exceeding US$100m.
Acting in a dispute regarding the accuracy of the calculation of tax on excess profits.
Completing the successful protection of large subsoil user’s interests in a large scale dispute regarding the estimation of reimbursable expenses under a Product Sharing Agreement.
Appealing tax inspection results regarding the transfer pricing of large subsoil users in Kazakhstan.
Acting on one of a few positive court decisions canceling the tax inspection results regarding the VAT allowance of false enterprises.
Successfully litigating on behalf of our clients, for the additional accrual of corporate income tax, corporate income tax for non residents paid at source, VAT, royalties and other taxes.
Ensuring the provision of preventive measures against any illegal actions of the Financial Authorities regarding the auditing of a large international trade company.
Appealing the notice given for the need for an extra tax audit.
Positively settling with the Tax Authorities a case regarding an illegitimately-accrued penalty on shares and the application of forced debt collection measures.
Providing ongoing protection of client interests in cases of potential administrative violations and assistance in appealing any negative results.

Providing assistance in planning international deals so as to avoid double taxation issues.
Advising on issues of tax optimization including issues on doing business through the favorable/low taxation zones.

Advising on issues regarding the execution of tax compliance including keeping tax records, presenting tax accounts, tax computation and tax payments.
Analyzing any tax-related consequences of making large scale asset purchases such as real estate and shares.
Reviewing tax compliance concerning the production of fuels and lubricants.
Advising regarding taxation of the hotel industry.
Providing legal opinions regarding the taxation of leased equipment.

Analysis of tax regime stipulated by contracts for subsoil use; provision of assistance with regard to accrued and paid taxes and special payments that are essential for subsoil users to make.
Providing legal opinions regarding tax issues arising from the purchase of a group of subsoil user companies by a foreign investor in Kazakhstan.
Providing legal opinions regarding the imposition of VAT in exploration work for a large scale foreign subsoil user.
Providing advice regarding amendments and additions for a subsoil user (contracts).
Providing ongoing assistance with regard to all tax issues for large scale oil service companies.

Providing ongoing advice regarding the avoidance of double taxation issues.
Providing general and ongoing legal help in putting together corporate income tax returns on behalf of a nonresident.
Obtaining confirmation for a large international air company to receive VAT exemption on equipment essential for air transportation according to legislation concerning air traffic.
Preparing advice for the branch office of a foreign company regarding the payment VAT for nonresident work.
Participation in planning and organizing tax payments for a nonresident regarding setting up a permanent establishment.
Advising a large international company regarding foundation & taxation issues surrounding the permanent establishment in Uzbekistan.
Providing advice regarding the taxation of a branch office for a fund based in Kyrgyzstan.
Advising a foreign company regarding the assessment of income tax for their team.

Completing a transfer pricing audit for a tax inspection by the Tax Authorities and protecting against unfavorable consequences.

Advising regarding tax & customs benefits and preferences when making investments.
Providing legal support when signing investment contracts for a range of production companies.

Registering the procedure connected with delivering telecommunication equipment to Kazakhstan with Customs bodies.
Preparing a legal opinion regarding customs payments with regard to the import of vehicles.
Providing legal help regarding the customs import registration of chemical products for an oil service company.
Advising a Russian company regarding customs, finance leasing, excisable rate and customs payments.
Analysing a Memorandum of understanding between the Committee of Customs Control and an Airline Company operating in Kazakhstan.