The story of how an audit by the global law firm Dictum saved an international IT business from a tax storm 🌊💼

📊 Imagine a classic modern business: a company in Kazakhstan successfully runs advertising and marketing campaigns for clients throughout Central Asia. The company’s founder is a well-established organization based in the UK.

💶The business model seemed logical and convenient. Clients from Kazakhstan and Uzbekistan transfer funds.
The Kazakhstani company takes its net commission and transfers the advertising budget itself to the British “parent company.” The parent company then pays Google and Facebook directly. Everything works as intended: budgets are rolling in, and profits are growing. And so the company decides to take the logical next step—to pay out its first dividends to its British founder.

☝️ But before doing so, the client decided to play it safe and turned to Dictum for a final review. And for good reason. When our lawyers took a look “under the hood” of this model, it became clear: the business was navigating a minefield.

Here are three pitfalls we identified and helped neutralize:

💥 Pitfall #1: The Illusion of “Ordinary Expenses”

The money flowing from Kazakhstan to the UK was treated as ordinary advertising expenses. But the tax authorities see it differently: these are transactions between related parties. If the documents were put together “on the fly,” the tax authorities would simply exclude these amounts from expenses. The result? Artificially inflated profits in Kazakhstan and exorbitant taxes “out of nowhere.” We immediately set about rewriting the contracts so that every cent would be justified.

📊 Stumbling Block #2: Hidden Transfer Pricing

Since money flows between a resident and a non-resident, this is a clear case of transfer pricing. The client believed that as long as his revenue hadn’t reached $43 million per year, he didn’t need to file reports, so he could relax. However, the law is strict: even if you don’t file a report, internal TP documentation must be kept in a safe. The tax authorities can request it at any time, and failing to provide it results in a massive fine. Now our client has it.

📉 Stumbling Block #3: Goodbye, 0% on Dividends

The client was operating under the old rules, when dividends could be withdrawn without any hassle. We opened his eyes to the new reality: the preferential 0% rate has been permanently eliminated as of January 1, 2026 (and even then, it applied only to local residents). For non-residents, a strict progressive tax scale now applies: up to $2 million—pay 5%; anything above that—pay 15%. We calculated the financial model for these payments in advance so that the tax amount wouldn’t come as a shock to investors.

Thanks to a timely audit, the company received a clear roadmap: how to pay taxes, how to file reports, and how to scale up in Central Asia without fear of tax authorities or currency controls.

❗️Are you building an international business or planning to enter new markets? Don’t wait for the tax authorities to find your weak spots. Message us via Direct or contact Svitlana Moroz (@svitlana_moroz) on Instagram or Telegram — @morozsvitlana. We’ll break down your business model step by step!