Alert on the decision of the Appeal commission of the Ministry of finance on tax dispute
On 24 November, 2023 the Appeal commission of the Ministry of finance of the Republic of Kazakhstan (the ‘Appeal Commission’) issued a decision on the tax dispute concerning transfer pricing control of a loan agreement.
Oil & Gas Comparative Guide 2024: Kazakhstan
GRATA International Partners Yerbolat Yerkebulanov and Leila Makhmetova, as well as Senior Associate Lyazzat Zhilkibagarova, participated in the preparation of the Kazakhstani chapter in Oil & Gas Comparative Guide by Mondaq
Review of the Ruling of the Supreme Court of Kazakhstan on a Tax Dispute
On 17 January 2024, the Administrative Collegium of the Supreme Court issued a ruling on a dispute relating to the taxation of Kazakhstan-source income of a non-resident who also has a registered permanent establishment in Kazakhstan
05.02.2024
Issues of sanctions and countersanctions have been one of the main topics for discussion during the last 3 years. Belarus followed Russia and adopted the list of so called “unfriendly states” by the Resolution of the Council of Ministers of the Republic of Belarus "On the List of Foreign States Committing Unfriendly Acts against Belarusian Legal entities and/or Individuals"N209 dated 06.04.2022.
Review of amendments to the legislation on the application of the Special Tax Regime of Retail Tax
In order to implement the Address of the Head of State dated September 1, 2023 "The Economic Course of Just Kazakhstan," the list of types of activities permitted for the application of the special tax regime for retail tax has been expanded. By the Government Decree №1240 dated 29 December 2023, the list has been expanded from 190 to 364 types of activities.
Permanent establishment registration process
Permanent Establishment is defined in Article 6 of the Corporate Income Tax Law and Articles 5 and 7 of the “International Convention on the Prevention of Double Taxation and Tax Evasion on Income and Capital”. In short, a PERMANENT ESTABLISHMENT is a unit that fully or partially conducts the activities of a taxpayer in Mongolia.
The law of the free zone
The purpose of this law is to set out principles pertaining to establishment, reorganization and dissolution of Free Zone, their location, management powers, control systems, and determines the legal basis for taxes, customs, entry/exit clearance, registration of legal entities and individuals, and employment to be adopted at Free Zone and regulates the relations connected therewith.
Overview of planned amendments to the Rules for Refunding Excess VAT
GRATA International law firm presents to your attention an overview of the main amendments and additions to the draft order of the Minister of Finance of the Republic of Kazakhstan dated March 19, 2018, № 391 «On Approving the Rules for Refunding Excess Value Added Tax and Applying a Risk Management System to Confirm the Accuracy of the Amount of Excess Value Added Tax, as well as Risk Degree Criteria» (hereinafter – the «Rules»).
Universal declaration in Kazakhstan
Since 2021, Kazakhstan has launched the universal declaration of income as part of the implementation of the Plan of the Nation - 100 concrete steps in the Republic of Kazakhstan
Tax control and appealing its results in Mongolia
The Tax Administration shall conduct tax audits in accordance with both general and special guidelines. These audits will be assigned and carried out in a comprehensive or partial manner, ensuring compliance with international standards and legislation as specified in Article 41.2 of the General Law on Taxation.
Tax control and appealing its results in Moldova
The need to know the types and/or forms of tax control is important for legal entities. It is very important for the party under verification to know its rights and obligations as a taxpayer in the event of a tax audit. Failure to comply with them can result either in the violation of rights, or in the application of coercive measures by the control authorities (by applying fines, stopping operations on company’s bank accounts, etc.). On the other hand, the taxpayer’s very good knowledge of his rights can help to avoid abuse by the authorities.
Tax control and appealing its results in Georgia
Tax control can be performed only by tax authorities. Tax control procedures shall not reasonably disturb the ordinary course of business of a taxpayer and shall not suspend its activity. The types of tax control are current control and tax audit. Re-audit of an already audited matter is prohibited without a judge’s order except matters for which a person files an adjusted tax return for an already audited period.