Lawyers of SIGNUM’ “Dispute Resolution and Litigation” practice area have represented the interests of the largest international airline company against the local state revenue department in the case of a CIT assessment in the amount of approximately USD 1.3 million as a result of a tax audit concerning the issue of international taxation.
Given the long court proceedings and refusal to grant approval of the requirements in the first, appellate, and cassation instances, in the review process of the supervisory complaint in the Supreme Court, the court has agreed with our arguments on the necessity for the cancellation and revision of judicial acts due to newly discovered circumstances. As a result of the cancellations of court decisions, the court of the first instance has made a decision on the legality of applying the Double Taxation Treaty. In addition,the court has recognized the notification of tax authorities on CIT tax assessments in the amount of more than USD 1.3 million as illegal.
Victoriya Trofimovich notes: “Our team has done a great job. It was a long process. Together, we have achieved the reconsideration of the case due to newly discovered circumstances, hence, more than 3 years after the consideration of the case on its merits. This is an unprecedented case, when newly discovered circumstance is deemed as an international treaty among the tax authorities of Kazakhstan and the United Kingdom within the Double Taxation Treaty”.