Tax & Investments

With extensive experience in tax law, Linkage & Mind offers comprehensive solutions to minimize risks through tax structuring of transactions in the most optimal way. We offer general and stand-alone tax advice to ensure our clients do not pay more than it is required.

Lawyers of Linkage & Mind consult large companies in Kazakhstan, as well as global corporations, banks and institutional investors on complicated questions of interpretation and application of tax legislation, tax planning and advice, corporate and international taxation, stamp duties, indirect taxes, property and local tax matters.

As we saved millions of dollars for our clients by optimizing taxes, we became the most awarded Kazakhstan law firm in tax law. When we are confronted with a problem, we try to find the most effective solution by thinking outside the box. We stand in courts against incorrect charges by the tax authorities for our clients. We carry out the optimization of taxes to protect the interests of companies, their structures and cash flows in debt financing, restructuring, swaps, securitization and other transactions.

Our Services:

Tax Consulting

We advise on a variety of tax issues, such as:

  • application of the law on corporate income tax, VAT, excise tax, property tax and other taxes
  • taxation of M&A transactions
  • taxation of groups of companies
  • taxation of subsoil users
  • taxation of transactions on securities market
  • use of tax deductions and exemptions
  • VAT refund
  • taxation of non-residents on income from sources in the Republic of Kazakhstan
  • taxation of permanent establishments of non-residents
  • taxation of natural persons
  • customs duties and indirect taxes within the Customs Union
  • taxation of real estate in asset management  transactions, with commissions and agency agreements

International taxation

Complex international mergers and acquisitions, investment and financing projects require professional advice on domestic and international taxation. We offer a wide range of solutions for the compliance of the companies with the ever-changing international tax environment, including:

  • advising on the application of double taxation treaties between Kazakhstan and other states
  • advising on the structuring of foreign assets in terms of tax optimization, including the choice of the appropriate jurisdiction of the legal form of companies, assistance in the realization of the projects
  • tax due diligence of the representative offices and branches of non-residents in the Republic of Kazakhstan
  • analysis of interest and dividend payment , development of funding and repayment  structures, including deals with various financial instruments
  •  tax disputes relating to taxation of foreign companies and representative offices
  • development of step-by-step plans for mergers and acquisitions with foreign holding companies

Tax Disputes

Our lawyers assist taxpayers in resolving various legal disputes. The judgments obtained in our cases are of great importance, not only for the companies we represent, but also for the wide spectrum of taxpayers as they change and improve tax legislations. In recent years, we have helped our clients save millions settling disputes in and out of court.

Our practice in tax dispute resolution includes the following services:

  • legal assistance during tax audits (analysis of legislation and primary documents, drafting responses to tax authorities, preparation of documents, support in negotiations with tax authorities)
  • appealing the results of tax audits
  • administrative appeal against the actions and decisions of tax authorities
  •  responding to the notification of tax authorities
  • defining the strategy and tactics of dispute resolutions based on tax audits results, either with tax authorities or in courts
  •  representation of companies in courts of all levels (preparation of statements, responses, objections, gathering evidence base)
  •  appeal of court decisions in courts of higher authority

Investment and Tax Privileges

Linkage & Mind lawyers have extensive experience in tax consulting in investment projects and investment tax preferences.

Our services:

  •  structuring investment projects from the standpoint of existing tax rules and tax preferences
  •  maintenance procedures for receipt of investment and tax incentives (preparation of documentation, feasibility studies, and negotiations)
  •  representing companies and trade associations in state bodies in the discussion of tax matters affecting their interests, filing the legislative initiatives on tax issues
  • consulting, tax and legal representation of foreign companies on tax issues

Tax Legislation Drafting

The firm's lawyers have extensive experience in drafting laws concerning interests of companies and business associations. We are participating in  tax law drafting. Our services in the field of legislative work include:

  • identification of  problems in  tax law and practice, requiring legislative changes
  • analysis of international practice of legal regulation of tax relations
  • preparation of the concept of amendments to the tax laws and their economic and legal analysis
  • drafting laws and regulations under the requests of the competent authorities
  • expert legal support when draft of law is under consideration at Government
  • organizing discussions and meetings on the issues addressed in the draft of the law
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News Projects

December 09, 2016

Linkage & Mind represented the interests of Strabag during the negotiations with its Kazakh partner and reached out of court settlement of the dispute on compensation Kazakh partner’s debt 2 000 000 USD.

November 05, 2013

Linkage & Mind assisted a Spanish company TYPSA to open a branch in the city of Astana.

October 31, 2013

L&M participated in the first conference of Austrian managers and investors of CIS in St. Petersburg.

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Private investment company

Comprehensive legal support in structuring of joint mining project (rare-earth metals) in Kazakhstan together with foreign investor and  national company ( Drafting of memoranda and agreement on cooperation in view of protection and prevention of diluting of Client’s participatory share; preparing legal opinion on structuring of group with a view of tax efficiency and IPO of a holding company.

InterFood

Advising on obtaining investment and tax preferences and governmental support of Interfood projects.

Siavele Developments Kazakhstan LLP

Comprehensive legal support of activities of LLP (cororate, tax, labour, commercial issues).

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Tax law firm of the year  2011, 2012,2013  by CorpINTL, Global Law experts, M&A Global