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      The global tax landscape is evolving rapidly. Transparency and compliance requirements are increasing, and OECD initiatives to counter Base Erosion and Profit Shifting (BEPS) are being implemented. These developments directly affect both Kazakhstan-based groups with foreign operations and international investors in Kazakhstan. 

      Businesses must reassess holding and financing structures: strategies based on low-tax jurisdictions are becoming less effective, and requirements often differ across countries.

      In this context, improper structuring can lead to excessive tax burdens or penalties from tax authorities. At the same time, well-planned strategies preserve opportunities for legitimate tax optimization.

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      Find out how KPMG's expertise can help you and your company.

      Challenges our clients face: 

      01

      Inefficient company structures from a tax perspective  

      02

      Excessive tax burden when financing international operations 

      03

      Lack of a clear strategy for profit allocation and exit from investment projects (e.g., sale or liquidation) 

      04

      Non-compliance with tax requirements when entering new markets or structuring cross-border transactions 

      05

      Underestimating tax consequences of acquiring foreign assets 

      06

      Difficulty complying with international tax obligations due to limited resources 

      How KPMG helps

      KPMG’s International Tax practice offers a full range of services to address these challenges:

      • Planning investment and asset structures in Kazakhstan and abroad, aligned with business objectives and recent legislative changes
      • Structuring financing flows and designing profit allocation strategies considering tax and currency regulations
      • Analyzing group structures in light of Kazakhstan legislation and OECD BEPS initiatives • Identifying controlled foreign companies (CFCs) and related tax obligations in Kazakhstan
      • Identifying controlled foreign companies (CFCs) and related tax obligations in Kazakhstan
      • Assisting with foreign tax credit planning and reclaiming withholding taxes under tax treaties
      • Preparing expert tax opinions on international tax matters
      • Developing exit strategies for investment projects and supporting M&A transactions (mergers and acquisitions, asset purchases and sales, etc.)
      • Ensuring tax compliance when entering Kazakhstan or other markets, allowing clients to focus on business growth

      Why clients choose KPMG: 

      01

      Our teams include experts in taxation, law, and accounting, providing a holistic approach 

      02

      Extensive experience in cross-border projects across multiple industries 

      03

      Global presence gives clients access to local expertise in relevant jurisdictions

      04

      We go beyond advisory: we understand industry specifics and international tax trends, helping clients mitigate risks and realize opportunities 

      Contact

      Assiya Atekeyeva
      Assiya Atekeyeva

      Director, Tax & Legal

      KPMG Kazakhstan