In Focus: Assel Ilyassova on Tax Law and Practice
The pdf version of the interview is available below:
1. How did you come into tax law, and what motivated you to choose this field?
To be honest, it wasn’t exactly love at first sight. At university, I was more interested in civil law, and my initial career plans were aligned with that field. But circumstances led me to take a position in the tax authorities, where I was introduced to tax legislation and the practical workings of the tax system. It was through that hands-on experience that tax law truly caught my interest.
In my view, tax law is more closely connected to business and the economy than any other legal field. It’s not enough to know the law — you need to understand the economic rationale behind it: how a business is structured, how decisions are made, and how government policy influences those decisions. That perspective transforms you from a legal technician into a strategic advisor.
2. Do you have professional role models — people, approaches, or cases that inspire you?
I’m most inspired by people who not only perform their professional duties well, but who also strive to bring value to society through their work. As for legal cases, I’m always impressed by those that not only protect the client’s position but also lead to a shift in established practice. The feeling that your work has meaning not just for the client, but for the system as a whole, is a powerful motivator.
3. What professional principles are most important to you?
In people, I value integrity and humanity above all. In the professional environment — regardless of the industry — I believe conscientiousness is critical. In most cases, a truly conscientious professional is also a person of integrity. Professional good faith is impossible without personal integrity, which forms its very foundation.
4. What changes in tax regulation and tax administration, in your view, have had the greatest impact on businesses in recent years?
One of the most significant developments has been the active digitalization of tax administration, which accelerated in response to the pandemic lockdown in 2020. This transformation included several aspects: the expansion of electronic services, increased reliance on desk audits, the introduction of automated cross-checking, and the transition to online court proceedings. In my view, these changes have had a positive impact on how businesses interact with the government.
5. What typical challenges do international companies face when entering the Kazakh market?
First and foremost, in my opinion, companies face challenges related to the way tax authorities apply legal norms, particularly those stemming from international tax treaties. Often, the core issue is not the norm itself, but how it is interpreted and how documentary evidence is assessed by the authorities.
Another major challenge is the presence of so-called “hidden” administrative barriers: frequent and unpredictable changes to tax legislation, a lack of consistent enforcement practice, and limited predictability in the behavior of regulatory bodies.
One striking example is the amendments to the Tax Code adopted in late Q1 2022, which retroactively took effect from the beginning of the year and revoked certain tax incentives. From the perspective of legal certainty, such retroactivity is clearly unacceptable, and these changes primarily affected international businesses.
In many cases, it is precisely the way laws are applied — often inconsistently, rigidly, or subjectively — that creates these hidden barriers. For international companies, such informal obstacles are often more burdensome than formal tax obligations. As a result, entering the Kazakh market requires a high level of adaptability and a well-designed tax compliance framework from the very outset.
6. What challenges do you most frequently encounter when dealing with tax authorities?
As I’ve mentioned earlier, one of the key challenges is the way tax authorities apply legal norms. In my view, the causes are complex and systemic. Addressing them requires more than isolated fixes — it calls for a comprehensive reform of the internal processes within the tax administration.
7. How do you assess the role of judicial practice in shaping tax enforcement in Kazakhstan?
Judicial practice has played an increasingly important role in the tax field following judicial reform and the establishment of specialized administrative courts. One could say that the judicial mechanism in this area has been revitalized.
Today, administrative courts play a key role in correcting and shaping tax enforcement practices. We are seeing positive developments: courts have become more impartial and substantive in their handling of disputes between taxpayers and the state bodies, the accusatory bias is gradually receding, and legal reasoning in judgments has become more robust. Courts are now more transparent and more clearly focused on protecting taxpayers' rights. All of this has a positive effect on the business environment and, ultimately, on Kazakhstan’s investment attractiveness.
Notably, the current success rate of tax disputes resolved in favor of taxpayers is around 60%, whereas prior to the creation of administrative courts, this figure was significantly lower and in some regions approached zero.
8. How do you assess Kazakhstan’s role in the global tax architecture? Is foreign investor interest changing?
In recent years, particularly amid regional geopolitical shifts, interest in Kazakhstan from foreign investors has grown noticeably. The country is seen as a relatively stable jurisdiction, and the government has made visible efforts to create a more favorable business environment.
In tax terms Kazakhstan is actively implementing global initiatives: it has joined the Multilateral Convention (MLI), is implementing BEPS measures, and is striving for greater transparency. These steps strengthen Kazakhstan’s position as a participant in the global tax system.
At the same time, I believe the ongoing tax reform — including the draft of the new Tax Code — raises concerns. If adopted in its current form, the new code would place Kazakhstan among the higher-tax jurisdictions in the region. This could undermine the country's competitiveness, particularly as neighboring countries are also seeking to attract investors by offering more favorable tax regimes.
Given the existing tax risks, administrative burdens, and inconsistent enforcement practices, the introduction of higher tax rates could significantly reduce Kazakhstan’s investment appeal. In that scenario, investors may prefer alternative jurisdictions that offer greater predictability and more competitive tax frameworks.
9. What qualities do you consider essential for a successful career in tax law today?
In my view, one of the most essential qualities is the ability to see the bigger picture — to go beyond the wording of a legal provision and understand the broader context, business realities, and the consequences of legal decisions. The second is critical thinking — the ability to ask questions, challenge assumptions, and work with complexity. The third is flexibility, adaptability, and a willingness to learn every day — because nothing stays static. These qualities, I believe, are not only vital for tax professionals, but increasingly important in any modern career.
10. What advice would you give to young lawyers just starting their careers?
Don’t be afraid of complexity, and don’t hesitate to ask questions — even if they seem basic. Real understanding begins with curiosity and a desire to dig deeper. Try to go a little beyond what the current task requires: take an interest in the logic behind the process, not just the formal outcome. In my experience, this mindset is often noticed and appreciated — and it opens the door to faster professional growth.
