Paper 2


  • Course location: Almaty, Kazakhstan
  • Lecturer: JUDr. Tomas Balco, LL.M., FCCA
  • Price: please contact Our Team at
  • Duration:  3 Days of courses and ongoing thesis supervision (Spring 2016)
  • Materials: hard copy of study materials and access to online library

Course description

The course gives overview of interaction between international tax law and national tax law in Kazakhstan and deepens the student’s understanding of the specifics of International Taxation and Transfer Pricing in Kazakhstan. This course also prepares students for writing a thesis. Apart from ADIT students, this course is recommended for  practitioners dealing with cross border tax issues in Kazakhstan.

This course is structured in 2 modules:

  • Course – 3 days
  • Thesis  – composed of:
  • Assistance with Thesis topic selection
    •  Synopsis assistance
    •  Structure development
  • Research and resources assistance
  • Review of 1st, 2nd and 3rd drafts
  • Discussions in person and remotely
  • Presentation of thesis to evaluation committee
  • Independent reviewer evaluation and final feedback

Day 1: Introduction to International Taxation in Kazakhstan 

  • 1.1. Fundamental Principles of International Taxation in Kazakhstan
  • 1.2. Kazakhstani Tax Treaty Network and its differences and similarities to OECD and UN MTC

Day 2: Special provisions on International Taxation in Kazakhstan

  • 2.1. Permanent Establishment in Kazakhstan and Attribution of Profits and Allocation of head office expenses
  • 2.2. Application of Kazakhstani Tax Treaties on selected types of transactions

Day 3: Anti-avoidance rules in Kazakhstan

  • 3.1. Transfer Pricing in Kazakhstan
  • 3.2. Thin-capitalization rule
  • 3.3. CFC rule
  • 3.4. Case Law and Miscellaneous topics

Writing a thesis

If the candidate has chosen to submit a  thesis instead of sitting Paper II, the subject matter of the thesis must be related to international tax from the perspective of the country of the candidate’s choice (e.g.“Kazakhstan”).

The thesis must be personal to the author. This means that the thesis must contain the author’s own analysis of the issues under consideration and/or should analyse existing material on the subject matter in a new way.

The thesis must be fully referenced. This means that all books, articles and other sources used must be cited in the text by way of footnote. Where quotations are used these should be clearly identified as such and properly referenced.

The thesis should normally be between 15,000 and 20,000 words. The thesis should be presented in accordance with the instructions in the Thesis Guidance notes. Candidates taking our course and also using our thesis assistance will get our support from A-Z – assistance in choosing the topic, submitting the synopsis, on-going support with support materials, repeat review and even trial evaluation by our team of experts.

Read more about Thesis option: 

In-house training are available. Please contact Our Team for further details at 

Contact Our Team at to register for preparatory ADIT courses.

Consult CIOT website for deadlines to register for ADIT exams!

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