Tax advice in Kazakhstan

Konsu is a professional company specializing in tax consulting and tax compliance.

We help companies minimize risks and save money. We will be happy to help optimize tax payments and are always ready to advise on taxation issues in Kazakhstan.

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Tax advice

Application of indirect taxation principles in the EAEU, including:

  • application of indirect taxes when exporting goods,
  • procedure for levying indirect taxes when importing goods,
  • the procedure for levying indirect taxes when performing works and rendering services.

Application of the international double taxation treaty between Kazakhstan and Russia

  • Determination of resident status by agreement
  • Establishment of a permanent establishment
  • Taxation of dividends, interest and royalties
  • Taxation of income from real estate
  • Procedure of tax crediting (elimination of double taxation)

Application of the Multilateral Convention (MLI)

Helping to reduce the risks of liability

Indirect Tax

Indirect taxes remain one of the most complex and dynamic evolving areas of tax regulation. Incorrect determination of tax liabilities related to VAT and cross-border transactions can lead to significant tax risks and financial losses for businesses.

Our team assists companies with indirect tax matters, taking into account industry specific considerations, international aspects, and tax authority practices.

Our services include:

  • Consultation on VAT tax matters;
  • analysis of tax implications arising from domestic and cross-border transactions;
  • determination of the place of supply for goods, works and services;
  • assessment of the applicability of tax exemptions, incentives and special tax regimes;
  • support in relation to import and export transactions involving goods and services;
  • VAT consultation related to transactions with non-residents;
  • review of transaction structures and contractual arrangements aimed at minimizing tax risks;
  • conducting VAT reviews and diagnostics;
  • assistance with VAT refund procedures;
  • development of practical recommendations for tax risk mitigation and process optimization;
  • assistance with challenging the results of tax audits and disputes with tax authorities.

Mergers and Acquisitions

Transactions involving the acquisition, sale, reorganization, and restructuring of businesses require a comprehensive assessment of the tax implications at every stage of the project. Insufficient analysis of the transaction structure, tax obligations, and potential risks can lead to significant financial losses, disputes with tax authorities, and a reduction in the asset’s investment appeal.

Our team supports clients in local and international transactions, including business acquisitions, asset sales, corporate restructurings, investor fundraising, and intra-group reorganizations.

We assist clients in assessing tax risks, analyzing transaction structures, and developing practical solutions that take into account the project’s commercial objectives, applicable legislation, and industry-specific considerations.

Our services include:

  • conducting legal, tax and financial due diligence reviews of businesses;
  • assessment of tax risks and potential liabilities prior to transaction closing;
  • preparation of vendor due diligence;
  • support with pre-sale business preparation processes;
  • analysis of tax aspects related to acquisitions of assets, shares and participatory interests;
  • analysis of tax implications arising from intra-group restructurings and reorganizations.

We provide a practical, business-oriented approach that enables our clients to make informed decisions and effectively manage tax risks when executing transactions and investment projects.

International Tax

Modern international tax practices require businesses to adopt a comprehensive approach to structuring cross-border operations, managing tax risks, and complying with the requirements of various jurisdictions. Increased global tax transparency, the development of BEPS initiatives, the exchange of tax information, and heightened focus by tax authorities on international structures significantly influence approaches to business operations and investment activities.

Our team assists Kazakhstani and international companies, investors, and private clients with matters related to international taxation, corporate structuring, and cross-border transactions, taking into account local legislation, international agreements, and the commercial objectives of the business.

Our services include:

  • analysis of international tax implications arising from cross-border transactions;
  • development and assessment of holding, financing and operational structures in Kazakhstan, Russia, UAE;
  • consultation on international corporate structuring and asset holding arrangements in Kazakhstan, Russia, UAE;
  • support with international financing arrangements and intra-group transactions;
  • analysis of tax aspects related to business reorganizations and restructurings;
  • assessment of permanent establishment (PE) risks for foreign companies;
  • advisory on corporate and individual tax residency matters;
  • analysis of the applicability of double tax treaties;
  • advisory on taxation of dividends, interest, royalties and other cross-border payments;
  • support with profit repatriation structures and withholding tax (WHT) matters;
  • analysis of international tax compliance and disclosure requirements;
  • analysis of tax aspects related to ownership and transfer of assets, including succession and private wealth matters;
  • assistance with tax refund procedures and application of international tax reliefs and incentives.

We aim to develop practical and sustainable solutions that enable our clients to effectively manage their international tax obligations, mitigate tax risks, and ensure compliance with applicable laws and regulations.

Corporate Tax

Companies face a wide range of tax issues on a daily basis, arising from their day-to-day operations, the implementation of new projects, the structuring of transactions, and interactions with tax authorities. Changes in legislation, evolving tax practices, and increased control by tax authorities require a timely assessment of tax implications and a comprehensive approach to tax risk management.

Our team provides support to Kazakhstani and international companies on corporate taxation matters, assisting clients in making informed business decisions that take into account legal requirements, industry-specific considerations, and the practical application of tax regulations.

Our services include:

  • Ongoing tax advisory services on corporate tax matters;
  • Analysis of the tax implications of business and cross-border transactions;
  • Structuring of business models, agreements, and specific transactions;
  • Conducting tax health checks and tax risk assessments;
  • analysis of the correct application of tax legislation requirements;
  • support for issues related to tax accounting and document management;
  • analysis of the tax aspects of financing, intra-group transactions, and profit allocation;
  • advising on the application of tax incentives and special regimes;
  • assisting with the preparation and analysis of contracts from a tax perspective;
  • advising on industry-specific tax issues, taking into account the specifics of the client’s business;
  • providing support on tax compliance and interaction with tax authorities.

We focus on providing practical and effective solutions that enable our clients to mitigate tax risks, ensure compliance with legislation, and establish sustainable tax processes within framework of their business operations.

Astana International Financial Centre («AIFC»)

Astana International Financial Centre continues to serve as one of the region’s leading platforms for structuring international investments, financial projects and corporate structures. The AIFC’s special legal and tax regime provides companies and investors with additional opportunities in terms of tax efficiency, corporate structuring and cross-border operations.

At the same time, the application of the AIFC regime requires a comprehensive assessment of business structures, transaction flows and compliance with the relevant requirements applicable to tax incentives and exemptions.

Our team assists clients with tax structuring and application of the AIFC tax regime, considering project-specific considerations, the legislation of the Republic of Kazakhstan and the regulatory framework of the AIFC.

Our services include:

  • advisory on the application of the AIFC tax regime and available tax incentives;
  • analysis of tax exemptions available to AIFC participants;
  • analysis of tax aspects related to fintech and digital business activities within the AIFC framework;
  • assessment of tax implications arising from financing arrangements, intra-group transactions and profit distribution;
  • advisory on taxation of dividends, interest, capital gains and other types of income;
  • analysis of the applicability of double tax treaties;
  • assessment of tax risks and compliance requirements related to AIFC tax exemptions and incentives;
  • analysis of tax implications for foreign investors and international groups of companies;
  • advisory on the interaction between the AIFC regime and the general tax legislation of the Republic of Kazakhstan.

We help clients develop efficient and sustainable structures utilizing the advantages of the AIFC while maintaining an appropriate balance between tax efficiency, regulatory compliance and commercial business objectives.

Leading positions

Konsu is one of the leading consulting companies in Russia. We have been included in the following ratings of the rating agency Expert RA:

  • Top-10 in accounting outsourcing
  • Top-10 in payroll outsourcing
  • Top-15 in financial consulting
  • Top-15 in legal consulting

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