Managing Partner of KP Disputes, Ravil Kassilgov, participated in the Discussion Forum "Reform of Tax Legislation: New Realities for Business", organised by Fortune Partners.
During the session "Judicial Practice in Tax Disputes: Will There Be Changes?" he shared his perspective:
- With the new Tax Code, the number of cases challenging orders to initiate inspections will be significantly reduced.
- At the same time, appeals against the outcomes of inspections will, on the contrary, reach a new level.
Reasons:
1️⃣ The new procedure for initiating unscheduled inspections is based on the confidentiality of the criteria, which will complicate the appeal of such orders and shift taxpayers' focus towards challenging the results of inspections.
2️⃣ Previously, the majority of inspections were concentrated on "unreliable suppliers", but the State Revenue Committee is striving to broaden its scope.
If this shift occurs, judicial practice will begin to encompass issues that rarely reached the courts before: the Multilateral Instrument (MLI), the Principal Purpose Test, beneficial ownership of income, transfer pricing, and other matters of international taxation.
