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Practical handbook



Tax Disputes: A Guide to Judicial Practice.

Part 1. Effective Application of the Administrative Procedural Code

Edited by

R.A. Kassilgov


This publication opens the series of practical guides “Tax Disputes: A Guide to Judicial Practice. Part 1. Effective Application of the Administrative Procedural Code”, dedicated to key issues in the resolution of tax disputes. This volume focuses on the effective application of the provisions of the Administrative Procedural Code of the Republic of Kazakhstan in tax dispute cases.


Subsequent volumes in the series will address specific categories of tax disputes, including unreliable suppliers, international taxation, the Multilateral Instrument (MLI), royalties, dividends, intra-group services, transfer pricing, tax refunds, and other related topics.

Tax Disputes: A Guide to Judicial Practice. Part 1. Effective Application of the Administrative Procedural Code
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The guide has been prepared by lawyers of the law firm KP Disputes, specialising in corporate tax disputes. The authors’ objective was to create a practical and useful tool for their colleagues, applicable when challenging acts of the tax authorities.

The book includes:
  • an analysis of the application of the Administrative Procedural Code at the pre-trial and judicial stages;
  • extracts from judicial acts with commentary and practical conclusions;
  • dedicated sections on desk tax audits, tax inspections, tax monitoring of large taxpayers, and the refund of income tax to non-residents.
In addition, online resources are provided via QR links: collections of judicial practice and regulatory acts, samples of procedural documents, official clarifications from state authorities, articles, and educational video materials prepared by KP Disputes team.

The publication is intended for legal consultants, advocates, tax and finance directors, in-house counsels, accountants, tax advisers, and all professionals involved in tax audits and disputes.

The guide will be useful for:
  • Legal consultants and lawyers
  • Tax and finance directors
  • In-house lawyers
  • Accountants and tax consultants
  • and all professionals engaged with tax audits and disputes
Sections of the practical handbook

Section 1
Procedural aspects of challenging actions and acts of tax authorities


Section 2
Application of the principles and specific features of the administrative procedural code (APPC) in tax disputes (judicial practice)

Section 3
Challenging acts issued within the framework of desk tax audits
Section 4
Challenging the appointment and results of tax inspections
Section 5
Tax monitoring of large taxpayers
Section 6
Challenging decisions refusing the refund of income tax on applications submitted by non-residents
Supplementary materials
The main feature of the guide is the inclusion of supplementary materials accessible via QR codes. Under the title of each chapter or paragraph, a QR code is provided linking to additional resources:
  • Judicial practice (over 330 judicial acts)

  • Bulletins of the Supreme Court and reviews of judicial practice published in the Supreme Court’s Legal Information System
  • Samples of procedural documents
  • Official clarifications issued by state authorities

  • More than 30 educational videos prepared by KP Disputes team

Authors

The guide has been prepared by KP Disputes tax disputes team, specialising in corporate tax disputes.

The authors’ goal is to create a practical and useful tool for their colleagues, applicable when challenging acts of the tax authorities.

How to use the handbook?


Tax Disputes: A Guide to Judicial Practice. Part 1. Effective Application of the Administrative Procedural Code
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