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      We guide clients through every stage of a dispute, from the initiation of a tax audit to the appeal of tax audit results in pre-trial proceedings and courts of Kazakhstan. 

      As enforcement activity by the Kazakhstan authorities intensifies, businesses need advisers who combine procedural experience with deep technical expertise in domestic and international tax matters.  

      Our team assists clients in challenging the results of tax and customs audits, tax monitoring outcomes, and tax administration decisions, including desk audit notifications and unlawful actions or inaction of tax authorities.

      We also advise on disputes involving double tax treaties, permanent establishment, withholding tax, the Multilateral Instrument and the Eurasian Economic Union customs framework.

      A key strength of our practice is the integration of disputes, legal and tax capabilities. This allows us to defend clients’ positions not only from a procedural perspective, but also through detailed analysis of the underlying transactions, business model, contractual arrangements, supporting evidence and applicable tax rules.

      Submit RFP

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

      How we can help

      KPMG assists clients in resolving matters with tax authorities, including:

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      Guidance during tax audits and review of audit materials
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      Assessment of potential tax exposure, procedural risks and supporting evidence
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      Development of a tailored strategy to protect the company’s interests
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      Preparation of objections, appeals, statements of claim and other procedural documents
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      Pre-litigation and litigation appeals of tax audit results, desk audit notifications, tax authority decisions and audit orders
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      Challenges to unlawful actions or inaction of tax authorities
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      Representation in matters involving tax treaties, permanent establishment, withholding tax, customs valuation and EAEU customs rules
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      Technical input from tax, customs and transfer pricing specialists in contentious matters
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      Analysis of relevant case law and enforcement practice

      What the client receives

      Clients working with KPMG receive practical, evidence-based assistance focused on managing risk and protecting their business interests, including:

      • a clear dispute strategy tailored to the facts of the case;
      • high-quality preparation of procedural documents and legal position papers;
      • comprehensive assessment of tax, customs and procedural law requirements;
      • technical analysis of tax, evidentiary and litigation risks;
      • review of relevant case law, administrative practice and enforcement trends;
      • coordinated input from tax, legal, customs and transfer pricing specialists.

      Why KPMG

      KPMG combines courtroom and administrative litigation experience with technical expertise in tax, customs, transfer pricing, permanent establishment and withholding tax matters. This integrated approach helps clients navigate complex, high-value disputes in a structured and practical way, from the audit stage through to administrative and court proceedings.

      Contact

      sosnovskiy-vyacheslav
      Vyacheslav Sosnovskiy

      Partner, Tax and Legal

      KPMG Caucasus and Central Asia