Our offer to execute the audit of the export supplies of oil regarding the transfer pricing

“GRATA” Law firm would like to ask you to consider our offer to execute the audit of your transfer costs on the oil supply. We advise you to undertake an audit of the oil supply for the periods which weren’t checked by the local tax committee on the transfer question. The results of the last tax verifications proved that ready-prepared documents and arguments can help oil exporters to avoid the unfounded imposition of taxes and fines.
Taking into account the likelihood of the problem, we advise you to take preventive measures before the next tax verification.

Our work will consist of the following phases:

1)    The analysis of documents concerning to the export. In this phase our specialists will check documents for compliance with the legislation of the Republic of Kazakhstan. The result of this work will be writing comments and recommendations regarding your use of your oil purchase and sale contracts, accounts with buyers, business mail and others.

2)    The collecting of the information from official sources. If the information from your documents is not enough, we can obtain the necessary information from other sources. As you know, a local tax committee usually takes into account information from such experts as Argus Petroleum, Platts Crude Oil, Energy 2000 and other. “GRATA” Law firm has friendly relations with Argus Petroleum. This helps us to obtain their conclusions on the current market which may be influenced by each exporter's experience.

3)    Preparing documents for future verifications. We will collate the concerted accounts and all documents for its substantiation in one file. This will make finding documents and information easier during the tax verification

GRATA Law firm, by sending this offer, has as its aim being useful to your company. Through our extensive experience in transfer pricing, we can reliably protect your interests in future tax disputes.

To begin our specialists will need copies of the following documents:

1)    Cargo custom declaration;
2)    Invoices for dispatched oil;
3)    Supporting evidence for payments for the oil transport expenses (freight, demurrage, port fees, insurance and others);
4)    Bill of lading;
5)    The oil purchase and sale agreement;
6)    The prepayment and other agreements for oil supply. Agreements about accounts between your company and buyers;
7)    Information regarding the route of the oil transportation;
8)    Data about the market price of the oil. This is information from Platts (copy) for the verified period*;
9)    Data about the freight cost obtained from Petroleum Argus (copy)*.
* GRATA can obtain this information if necessary.