Additional Tax Assessment Following Transfer Pricing Control Audit

Our lawyers have successfully defended interests of a client (subsoil user) in litigation on tax dispute. According to the results of tax audit on application of transfer pricing, taxes in the amount of 800 mln. tenge were charged by the State Revenue Department (SRD). According to the SRD, the subsoil user during the oil export (1) wrongfully included some types of expenses into the differential, and (2) overcharged the amount of some types of expenses, included into the differential. According to results of the court proceedings, the court recognized that additional taxes were charged illegally and obliged the SRD to re-calculate the taxes taking into account supporting documents and data from the official source of information.