Tax Advisory

Almaty, Kazakhstan

Building on the firm's long-standing tax work across its corporate, finance and energy mandates, Unicase consolidated its tax capabilities into a dedicated practice led by Counsel Kaisar Yegizbayev, covering transactional tax, project and financing tax, international tax and treaty matters, AIFC structuring, tax disputes, and employment and personal taxation.

The team is regularly engaged on some of Kazakhstan's most significant energy transition and infrastructure projects, advising sponsors, contractors and borrowers on the tax implications of EPC, financing and consortium arrangements involving EBRD, ADB and other international financial institutions. Its work focuses on the issues that frequently determine bankability: permanent establishment and withholding tax exposure, double tax treaty relief, gross-up mechanics and the allocation of tax risk between project participants.

Drawing on the firm's AIFC experience since 2018, with lawyers registered as AIFC practitioners, the team advises on AIFC holding, financing and fintech platforms, the application of AIFC tax exemptions, and the tax treatment of digital asset and merchant payment models.

Working alongside the firm's Corporate and M&A, Banking and Finance, Energy and Dispute Resolution teams, the practice provides integrated legal and tax support from structuring and due diligence through to tax audits, administrative appeals and litigation. Integrated workstreams enable tax due diligence and transaction documentation to be delivered on compressed timetables, supported by document automation and AI-enabled knowledge tools that track legislative and treaty developments.

Kaisar Yegizbayev is regularly mandated on treaty analysis, AIFC holding and financing platforms, digital asset structures, major project financings and complex tax disputes.

Unicase's Tax Advisory practice advises international and domestic clients on the full range of Kazakhstan and cross-border tax matters, with particular strength in energy, infrastructure and project finance, AIFC structuring and digital assets.

Almaty, Kazakhstan

Services

Transactional and Corporate Tax

Digital Assets and Fintech

Tax Disputes and Controversy

Tax Incentives and Investment Preferences

Project and Financing Tax

Tax Opinions and Clarifications

International Tax and Double Tax Treaties

VAT, Customs and Indirect Taxes

Transfer Pricing

AIFC Tax and Structuring

Sectors

Energy and Renewables

Infrastructure and Transport

Banking and Finance

Tourism

Oil and Gas

Fintech and Digital Assets

Power Generation

Top Projects:

Advised Total Eren, the renewable energy arm of TotalEnergies, on the Kazakhstan tax aspects of the structuring and Phase II financing of the USD 1.2 billion Mirny project, Kazakhstan's first 1 GW wind farm with integrated battery storage, located in the Zhambyl region and financed by EBRD, Proparco, DEG and other lenders.

Advised a major Chinese bank on the Kazakhstan tax and regulatory aspects of a proposed cross-border financing to Silleno LLP, covering interest withholding tax, gross-up provisions, beneficial ownership and tax residence requirements, and the full exemption under the Kazakhstan–China double tax treaty, as part of a multi-jurisdictional credit assessment involving state-owned and international sponsors.

Advised UAB City Pay on the establishment of an AIFC-based cross-border holding and financing structure for operations across Lithuania, Kazakhstan, Georgia, Uzbekistan, Turkey, El Salvador, Tajikistan, Kyrgyzstan and ADGM, covering withholding tax, thin capitalisation, treaty relief and currency control, and the feasibility of USDT-denominated convertible loans under AIFC and Kazakhstan digital asset regulation.

Advised a leading French cable car technology provider on the Kazakhstan tax structuring of its participation in a USD 249 million cable car project for a Kazakhstan tourism development company, designing a consortium structure to mitigate permanent establishment and withholding tax risks under the Kazakhstan–France double tax treaty, and negotiating its acceptance by the employer.

Advised Almaty Power Plants JSC (ALES) on the Kazakhstan tax aspects of a USD 214 million coal-to-gas conversion project involving a combined-cycle gas turbine facility of up to 600 MW, covering tax risk allocation across EPC, contractor and financing arrangements with the Asian Development Bank, EBRD and the Development Bank of Kazakhstan.

Advised a major cryptocurrency exchange group on the Kazakhstan tax aspects of implementing its merchant payment model through an AIFC-regulated subsidiary, covering corporate income tax and VAT treatment, the availability of AIFC tax exemptions for digital asset platform activities, electronic invoicing (ESF) requirements and payment service provider arrangements, and recommending an official tax clarification.

Advised the purchaser on a USD 6 million share acquisition under an integrated legal and tax mandate, conducting tax due diligence alongside legal due diligence on a five-to-seven business-day timetable, preparing the share purchase agreement, analysing required regulatory approvals and assisting with completion, with findings informing transaction structuring and contractual protections.

Represented an international EPC contractor in Kazakhstan's oil and gas sector in a tax dispute arising from a thematic tax audit, with assessments exceeding KZT 3 billion, advising on permanent establishment, withholding tax under the Kazakhstan–France double tax treaty and limitation periods, and challenging the tax authority's delay in completing the audit in court.

Tax Advisory Practice in Telegram

@taxradar_unicase

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