SIGNUM’s Tax practice brings together lawyers and tax professionals with in-depth knowledge of Kazakhstan tax law and extensive experience advising international and domestic companies across a broad range of industries. We help clients assess the tax implications of business decisions, structure transactions and investments, manage tax risks, and protect their interests in dealings with tax and customs authorities.
In an environment of evolving tax legislation and enforcement practice, clients need advice that is clear, practical and commercially focused. We closely monitor legislative developments, court decisions and administrative practice, including the approaches taken by tax and other government authorities. This enables us to identify potential risks at an early stage and develop solutions tailored to each client’s business and industry.
SIGNUM has substantial tax experience across the energy and natural resources, mining, telecommunications, financial and other sectors. We advise on tax structuring and international taxation, support clients through tax audits and controversies, and represent them in complex negotiations and litigation. Our experience includes matters involving the tax stability of investment and subsoil use contracts and production sharing agreements (PSAs), transfer pricing, VAT, customs matters and the application of double taxation treaties.
Represented a major independent specialist company in Russia in challenging a tax authority decision concerning royalty assessments.
Represented one of the world’s leading suppliers of electromechanical equipment in challenging tax assessments totalling approximately EUR 600,000.
Represented a major company specialising in the design and construction of fibre-optic networks and water infrastructure in litigation challenging the results of a tax audit involving approximately USD 716,000.
Represented a production sharing agreement (PSA) operator in litigation challenging the results of a comprehensive tax audit, with additional assessments of approximately USD 20 million.
Represented an international airline in litigation challenging a corporate income tax assessment resulting from an incorrect application of a double taxation treaty. The amount in dispute was approximately USD 1.3 million.
Represented a uranium mining company in litigation challenging the results of a comprehensive tax audit involving approximately KZT 4 billion in additional corporate income tax, mineral extraction tax, property tax and other subsoil user payments.
Represented an international FMCG company in litigation challenging the results of a tax audit involving additional assessments of approximately USD 15 million.
Represented an international oil company in litigation arising from a transfer pricing tax audit involving additional assessments of approximately USD 2.5 million.
Advised a major dealer of specialised vehicles on the legal and tax aspects of an employee loyalty and incentive programme, including contractual matters, currency regulation, tax structuring and risk assessment.
Advised a key producing asset of an international oil and gas company listed on the London Stock Exchange on tax matters arising from its transition from exploration to commercial oil and gas production at a field in Kazakhstan.
Advised an international oil and gas company on potential tax disputes arising from the application of a special tax regime under a PSA in Kazakhstan.
Advised on tax matters related to the launch in Kazakhstan of a major digital platform connecting passengers with taxi service providers.
Advised the Kazakhstan subsidiary of a leading global uranium company on the legal and tax implications of newly introduced tax provisions.
Advised a foreign insurance company on taxation of reinsurance arrangements.
Advised one of Kazakhstan’s largest banks on taxation of insurance and reinsurance transactions.
Advised a Kazakhstan insurance company on taxation of insurance payments.
Advised a listed Kazakhstan oil and gas company on compensation arrangements, including taxation of compensation and insurance matters.
Advised an association of subsoil users on the stability of tax regimes established under subsoil use contracts in light of changes to Kazakhstan tax legislation.
Prepared a tax opinion for a PSA operator concerning the exclusion of certain costs from recoverable expenditures by the tax authorities.
Advised a major uranium producer on tax risks relating to deductions for corporate income tax purposes.
Prepared a legal opinion for an international telecommunications company on tax planning in connection with the import of software into Kazakhstan.
Advised and supported a telecommunications company in obtaining investment-related tax incentives and preferences.
Assisted a mobile operator in obtaining tax exemptions, incentives and preferences available under an investment project.
Advised on the tax implications of a sale of participating interests in a PSA project.
Advised one of the world’s largest bunker fuel and lubricants businesses in connection with the unlawful transfer of the client’s guarantee funds by the customs authorities to the state budget.
Challenged before the courts a decision of the Ministry of Finance of Kazakhstan concerning recognition of customs exemptions available to a PSA operator.
Represented an international oil company in a dispute with the customs authorities concerning additional export customs duties totalling approximately USD 10 million.
Represented an international FMCG company in litigation challenging the inclusion of royalties in the customs value of imported goods.
Represented a construction company in litigation challenging additional customs payments of approximately USD 1.5 million.
Advised a major European service company on the application of customs exemptions available under a PSA to the operator’s subcontractors.
Represented a client before tax and customs authorities in connection with the recovery of previously paid customs duties.
Advised a telecommunications company on customs clearance of imported software.
Advised an international service company on customs clearance of vessels imported into Kazakhstan.
Advised a major European company on tax and customs matters relating to operations in the Seaport Aktau Special Economic Zone.
Conducted comprehensive tax due diligence in connection with the indirect USD 21 million acquisition of a Kazakhstan subsoil user through a reverse takeover on the London Stock Exchange.
Conducted a tax review and assessed the compliance of a company’s tax accounting prior to the commencement of a tax audit.
Conducted tax due diligence and advised on tax matters arising from corporate transactions for a European oil and gas company operating in Kazakhstan.
Conducted tax due diligence and advised on tax matters in connection with the acquisition of a gold mining company.
Conducted a tax review of a combined heat and power plant in East Kazakhstan in connection with financing of its reconstruction by a major European bank.
Conducted a transfer pricing tax review for a major European oil and gas company.
Conducted a transfer pricing tax review for a Portuguese oil and gas company.
Advised a major uranium mining company on the application of Kazakhstan transfer pricing legislation.
Conducted a transfer pricing tax review for a UK oil and gas company.
Successfully represented a major German oil and gas company in transfer pricing litigation.
Advised a major uranium producer on the tax treatment and structuring of secondment arrangements, including cross-border tax implications in Kazakhstan and abroad.
Advised a European oil and gas company on potential liability arising from non-compliance with tax requirements applicable to personnel secondment arrangements.
Advised a major mining company on the development of an efficient employee remuneration system, including flexible benefit arrangements and other employment tax matters.
Prepared a legal opinion for a European oil and gas company on the tax implications of consultancy agreements and related risks for both consultants and the employer.
Conducted a retrospective tax and legal review of employment agreements with foreign employees of a major Canadian joint venture covering the five-year period preceding a tax audit.
Advised on taxation of individuals providing services outside traditional employment arrangements and on taxation of their income under Kazakhstan law.
Advised a uranium mining company on taxation and employee benefits applicable to individuals born or residing in designated ecological zones in Kazakhstan.
Advised a mining company on taxation of payments relating to disability, bodily injury and workplace accidents.
Advised one of the largest oil companies on VAT refunds in Kazakhstan and represented it in challenges to decisions of the tax authorities.
Represented a uranium mining company in litigation challenging the denial of a VAT refund of approximately USD 8 million.
Represented a foreign geophysical services company in litigation challenging an additional VAT assessment of approximately USD 300,000.
Advised a major German airline on VAT exemption matters.
Advised a major European telecommunications company on mitigating the risk of additional VAT assessments in Kazakhstan.
Advised a European service company on VAT matters under the revised tax legislation and on requirements applicable to suppliers to consortium arrangements.
Represented a major telecommunications company in litigation concerning the recovery of VAT from the Kazakhstan state budget.
Advised an international service company on VAT exemptions available under the North Caspian PSA and Kazakhstan law.
Advised a major Australian company on the tax implications of liquidating its Kazakhstan subsidiaries and exiting the Kazakhstan market.
Advised a French producer of syrups and liqueurs on tax structuring and tax obligations relating to its operations in Kazakhstan.
Advised a major Russian technology company specialising in plagiarism-detection technology on tax structuring for its entry into the Kazakhstan market.
Advised an international oil producer on the tax aspects of a corporate reorganisation ahead of an IPO.
Advised on taxation of a transaction involving the sale of 100% of the shares in an oil production company.
Advised on tax matters relating to listing and trading securities on the Kazakhstan Stock Exchange (KASE).
Advised a European oil and gas company on restructuring its presence in Kazakhstan in response to changes in Kazakhstan tax legislation.
Developed a corporate structure for a UK client taking into account the tax implications of conducting business through a Kazakhstan legal entity.
Advised an international telecommunications company on corporate and tax restructuring in Kazakhstan in connection with the merger of two major telecommunications businesses.
Worked alongside criminal defence counsel to advise and protect taxpayers in dealings with law enforcement authorities on matters arising from tax audits and tax liabilities.
Represented executives and employees of a European oil and gas company and provided legal defence throughout all stages of an investigation.
Advised and represented a mining company in its dealings with law enforcement authorities following a tax audit.
Successfully represented a major German oil and gas company in administrative proceedings arising from the results of a tax audit.
Advised a major German airline on various corporate and tax matters, including the application of the Kazakhstan–Germany double taxation treaty.
Prepared a legal opinion for a Kazakhstan founder of a UK company on taxation of his income and the application of the relevant double taxation treaty.
Advised a major international service company on cross-border payments and taxation of dividends and royalties.
Advised a major French food company on the tax implications of services relating to the preparation of a feasibility study, including review of the underlying agreement.