www.pwc.kz

Our Services

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Legal assistance and support during documentary and desktop tax inspections including communication with the state authorities

Preparation of the draft appeal (based on tax inspection results) to a higher tax authority

Assistance during administrative proceedings related to tax offences

Representation of clients at court

Expert evidential support at court hearings

Assistance with mutual agreement procedures (MAP) with foreign tax authorities

VAT refund

Other services

We are ready to assist Companies at all stages of a tax inspection as well as during the appeal process. Our team includes experienced Kazakhstan tax professionals proficient in pre-trial and judicial tax dispute resolution.

Tax Dispute Resolution Practice

Our competitive advantages

џ Our team have experience working for the tax authority.

џ Our tax team is specialized in different areas of tax, for example,international taxation, transfer pricing, indirect taxation. This enables us touse the right expertise.

џ Our tax team also has successful experience of lobbying our clients' interestsin the state authorities on issues related to subsurface use and customspayments, resulting in amendments to the legislation.

џ Working with our assurance and advisory colleagues, we bring relevantindustry expertise to bear on situations.

џ Our tax dispute resolution team is part of a global network. We draw on theirexperience and expertise when needed.

Our experience

џ We provided valuable assistance to two large oil џ We drafted the successful appeal and supportingcompanies in reducing CIT and EPT assessments from arguments for the branch of a foreign companyTP tax inspections. Assessments appealed successfully performing international freight forwarding services.were over USD 40 mln. Amounts appealed were USD 1.4 mln.

џ We assisted a large MNC large appeal the tax џ We provided assistance to international freightauthorities' decision on application of DTA provisions. forwarder company in CIT appeal. Amounts appealedAssessments appealed successfully were over USD 12 were USD 1 mln.mln withholding tax and penalties. џ We helped a client to successfully appeal

џ We assisted the branch of a multinational group appeal administrative fine of USD 300.000 within anregarding the allocation of head office general and administrative case related to CIT.administrative expenses. Assessments appealed џ We helped a large mining company confirm the fact ofsuccessfully were over USD 13 mln. export of goods and to implement a VAT refund of USD

џ We assisted the Kazakh subsidiary of an international 2 mln.bank to successfully appeal in respect of deductible џ We helped to develop (clarifying) amendments to theVAT, disallowed for offset, totaling USD 2.5 mln in tax legislation regarding application of RC-VAT to non-assessed taxes and penalties. residents' income given a presence of a branch in

џ We helped a large trading company, which exports Kazakhstan. Also PwC helped to develop the formulaagricultural products to implement a VAT refund of for calculation of production cost of accompanyingUSD 171.000. natural gas extracted from oil for CIT purposes.

© 2017 PwC. All rights reserved.

Our Tax dispute team

Dana Tokmurzina

Tel.: +7 (7172) 55 07 07

Email: dana.tokmurzina@kz.pwc.com Fax: +7 (7172) 55 07 08

Tel.: +7 (7172) 55 07 07

Email: bayan.utegenova@kz.pwc.com Fax: +7 (7172) 55 07 08

Manager, 9 years of experience in subsoil users disputes

Bayan Utegenova

Michael AhernPartner

Senior Manager, Transfer pricing

Tel.: ( )

Email: michael.ahern@kz.pwc.com

+7 727 330 32 01Fax: +7 (727) 244 68 68

Tel.: +7 (7172) 55 07 07 Fax: +7 (7172) 55 07 08Email: nursultan.nurbayev@kz.pwc.com

Nursultan NurbayevDirector, Tax dispute and Regulation practice driver, ADIT, Cand.Sc.Law, more than 8 years of experience in tax authorities of the RK

Manager, International taxation

Tel.: +7 (727) 330 32 00Fax: +7 (727) 244 68 68Email: zhanar.kumasheva@kz.pwc.com

Zhanar Kumasheva

Manager, FMCGMikhail Kovalenko

Tel.: +7 (727) 330 32 00Fax: +7 (727) 244 68 68Email: mikhail.kovalenko@kz.pwc.com

Manager, more than 7 years of experiencein tax authorities of the RK

Said Galibayev

Tel.: +7 (7172) 55 07 07

Email: said.galibayev@kz.pwc.com Fax: +7 (7172) 55 07 08

Artem PetrukhinPartner

Tel.: ( )

Email: artem.petrukhin@kz.pwc.com

+7 727 330 32 01Fax: +7 (727) 244 68 68