• 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 FMCG company in litigation challenging the results of a tax audit involving additional assessments of approximately USD 15 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 airline in litigation challenging a corporate income tax assessment resulting from the incorrect application of a double taxation treaty. The additional assessment was approximately USD 1.3 million.

• Represented an international oil company in litigation arising from a transfer pricing tax audit involving additional assessments of approximately USD 2.5 million.

• 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 one of the world’s leading suppliers of electromechanical equipment in challenging additional tax assessments totalling approximately EUR 600,000.

• Advised international oil and gas companies on disputes concerning the stability of special tax regimes established under subsoil use contracts and PSAs.

• Supported major subsoil users during comprehensive and thematic tax audits, including an audit involving potential additional assessments of approximately USD 50 million.

• Represented an international oil company in litigation against the customs authorities concerning additional export customs duties of approximately USD 10 million.

• Represented an international FMCG company in litigation against the customs authorities concerning 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 one of the world’s largest bunker fuel and lubricants businesses and assisted with the recovery of guarantee funds transferred by the customs authorities to the state budget.

• Challenged a decision of the Ministry of Finance of Kazakhstan concerning the application of customs exemptions available to a PSA operator.

• Advised a major European service company on customs exemptions available under a PSA to the operator’s subcontractors.

• Represented clients before tax and customs authorities in connection with the recovery of previously paid customs duties.

• Advised telecommunications and service companies on customs clearance of software, equipment and vessels imported into Kazakhstan.

• Advised a major European company on tax and customs matters relating to operations in the Seaport Aktau Special Economic Zone.

• 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 in Kazakhstan.

• Advised the Kazakhstan subsidiary of one of the world’s largest uranium producers on the legal and tax implications of changes to Kazakhstan tax legislation.

• Advised an association of subsoil users on the stability of tax regimes established under subsoil use contracts in light of changes to tax legislation.

• Prepared a tax opinion for a PSA operator concerning the exclusion of certain expenditures from recoverable costs by the tax authorities.

• Advised a major uranium producer on tax risks relating to deductions for corporate income tax purposes.

• Advised a major specialised vehicle dealer on the legal and tax aspects of an employee loyalty and incentive programme, including contractual matters, currency regulation, tax structuring and risk assessment.

• Advised on tax matters relating to the launch in Kazakhstan of a major digital platform connecting passengers with taxi service providers.

• Advised a foreign insurance company, one of Kazakhstan’s largest banks and a Kazakhstan insurance company on taxation of insurance, reinsurance and insurance payments.

• Advised a listed Kazakhstan oil and gas company on the tax treatment of compensation and insurance payments.

• Advised telecommunications companies on tax planning relating to software imports and on obtaining investment-related tax incentives and preferences.

• 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.

• Advised a buyer on the tax aspects of an M&A transaction involving the acquisition of an interest in a Kazakhstan hydrocarbons producer.

• Conducted tax due diligence and advised on tax matters arising from acquisitions of oil and gas assets by international investors.

• Conducted tax due diligence and advised on tax matters in connection with the acquisition of a gold mining company.

• Conducted tax reviews of companies and assessed the compliance of their tax accounting prior to tax audits.

• 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.

• Advised a Swiss investment fund on tax due diligence in connection with the acquisition of a mining asset.

• Conducted comprehensive transfer pricing tax reviews for major European oil and gas companies.

• Conducted a transfer pricing review for a Portuguese oil and gas company.

• Conducted a transfer pricing review for a UK oil and gas company.

• Advised a major uranium mining company on the application of Kazakhstan transfer pricing legislation.

• Represented international oil and gas companies during tax audits and litigation involving transfer pricing matters.

• Successfully represented a major German oil and gas company in transfer pricing litigation.

• Advised a Portuguese oil and gas company on tax-efficient structuring of income derived from oil sales.

• Advised a major uranium producer on the tax treatment and structuring of secondment arrangements, including tax implications in Kazakhstan and abroad.

• Advised a European oil and gas company on tax risks and potential liability arising from personnel secondment arrangements.

• Advised a major mining company on the development of an 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.

• Advised a uranium mining company on taxation of benefits and payments to employees 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.

• Represented a major telecommunications company in litigation concerning recovery of VAT from the Kazakhstan state budget.

• 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 and statutory requirements applicable to suppliers to consortium arrangements.

• Advised an international service company on VAT exemptions available under the North Caspian PSA.

• Advised international companies on tax structuring for market entry into Kazakhstan, including technology, digital, industrial and FMCG businesses.

• Advised a major Russian technology company specialising in plagiarism-detection technology on tax structuring for its entry into the Kazakhstan market.

• Advised a major Russian industrial equipment manufacturer on corporate and tax structuring for establishing operations in Kazakhstan.

• Advised one of the largest Russian online platforms and technology companies on the tax structuring of call-centre services provided outside Kazakhstan.

• Advised a major international software and delivery business on the tax structuring of a new project involving an intellectual property owner, project owner and service providers.

• Advised a French producer of syrups and liqueurs on tax structuring and tax obligations relating to its Kazakhstan operations.

• Advised a major Australian company on the tax aspects of liquidating its Kazakhstan subsidiaries and exiting 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 the tax aspects of restructuring its presence in Kazakhstan.

• Advised an international telecommunications company on the tax aspects of a corporate restructuring in Kazakhstan arising from the merger of two major international 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 at various 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 companies and senior management on potential administrative and criminal liability arising from compliance with tax obligations.

• Advised a major German airline on corporate and tax matters, including application of the Kazakhstan-Germany double taxation treaty.

• Prepared a legal opinion for a Kazakhstan founder of a UK company on taxation of income and 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 cross-border services relating to the preparation of a feasibility study.

• Advised international oil and gas and service companies on double taxation treaties, permanent establishment issues and taxation of cross-border payments.

• Advised international technology companies on tax structuring of cross-border service models and the use of intellectual property.