Legal consultants in tax matters

Protecting business
from tax
risks

We challenge tax assessments. We support tax audits. We overturn unlawful notices.

Tax status

ONLINE

Select your situation — we'll show a step-by-step action plan.

Results

Our results in numbers

All cases

+3 bn ₸

in tax assessments overturned

+50 M ₸

in fines prevented

+500 M ₸

returned to taxpayer accounts

+50

audits closed before starting

+30

audit notices overturned

+20

account and e-invoice unblocks enforced

Success Fee 30/70

Pay for the result,
not for the process

The advance covers the work: preparing procedural documents, court representation, correspondence with the tax authority. The main fee — only after the result is achieved.

If the result is not achieved — you don't pay the 70%. That means we only take on cases we're confident in.

30%

ADVANCE

For the work: documents, claims, hearings

70%

SUCCESS FEE

Only after a result on the case

Practice

Our cases

All cases
Construction · СМАСCourt

49 M ₸

in assessments overturned

Audit declared unlawful — protected CIT and VAT deductions

Situation

The tax authority excluded deductions of 49 M ₸ based on criminal proceedings against the counterparty's manager, without a sentence in legal force.

Action

Art. 264 of the НК РК and Supreme Court Normative Ruling No. 9 — exclusion is permissible only with a sentence. We assembled primary documentation and confirmed reality through the State Revenue Committee (КГД).

Result

The СМАС declared the notice unlawful. CIT of 23.6 M ₸ and VAT of 13 M ₸ overturned.

VAT / Taxpayer accountAdministrative

60.7 M ₸

balance restored

Error in VAT taxpayer account — secured restoration of the balance

Situation

Seven erroneous adjustments in the State Revenue Committee (КГД) information system understated the positive VAT balance by 60.7 M ₸.

Action

Filed a complaint via e-Otinish and a claim in the СМАС of Astana: inaction under the rules for maintaining the taxpayer account.

Result

By court ruling the taxpayer account was brought into line and erroneous interest reversed.

VAT / ReorganisationCourt

48.5 M ₸

in assessments and interest overturned

Unlawful VAT write-off after reorganisation

Situation

Two years after a merger the tax authority wrote off the transferred VAT balance and assessed 37 M ₸ plus 11 M ₸ of interest against the legal successor.

Action

We proved: obligations on winding-up reporting are personal (art. 62(2) of the НК РК); art. 429 of the НК РК does not apply to an active VAT payer.

Result

The СМАС granted the claim in full. Assessments of 37.1 M ₸ and interest of 11.4 M ₸ overturned.

Unscheduled audit · Pre-trialPre-trial

48 M ₸

in potential assessments prevented

Tax authority withdrew the unscheduled audit after our objections

Situation

The tax authority (ДГД) issued a preliminary decision on appointment of an unscheduled audit on mutual settlements with counterparties. Claims: VAT of 10.5 M ₸, CIT of 23.2 M ₸ and interest of over 15 M ₸. The preliminary decision was sent via WhatsApp late in the evening.

Action

We identified 4 grounds of unlawfulness: absence of the audited period (sub-clause 8) of art. 148(1) of the НК РК), unspecified subject of the audit, unmotivated conclusion on absence of origin of goods, outdated data on e-invoice (ЭСФ) blocking. Filed a formal objection with legal substantiation.

Result

The tax authority decided not to proceed with the audit. Assessments of VAT 10.5 M ₸, CIT 23.2 M ₸ and interest over 15 M ₸ — prevented without court proceedings.

Situation analysis

Have a tax question?

Get an initial analysis of your situation. We assess prospects and suggest a strategy — before signing a contract.