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145
Kambar MIZAMBAYEV,
chief expert of URZ KGZ MF RK
Within the implementation of the Law of the RK 
«About Government Procurements», the resolution 
of the government of the RK No. 300 of April 2, 
2014 the Committee on government procurements 
of the Ministry of Finance of the RK (further – the 
Committee) is defined as the uniform organizer of 
government procurements.
According to the Rules of carrying out electronic 
government procurements approved by the order of 
the Minister of Finance of the Republic of Kazakhstan 
on June 23, 2015 No. 378, the organization and 
execution of electronic government procurements 
of goods, works, services in the way of competition 
is carried out by a Committee on the basis of 
representation by the customer of a task.
The list of inventory, works, services on which 
the organization and execution of government 
procurements is carried out by the uniform organizer, is 
approved by the Order of the Minister of Finance of the 
Republic of Kazakhstan of December 9, 2014 No. 548.
The organization and execution of electronic 
government procurements of goods, works, services 
which are carried out in the way of competition by 
the uniform organizer provides performance of the 
following consecutive stages:
- the approval of the competitive documentation 
containing the technical specification approved by 
the customer, the draft agreement on government 
procurements, the composition of of experts 
commission or an expert and its formation on a web 
portal of government procurements;
- the statement of the composition of a contest 
committee and designation of the secretary of a 
contest committee from among a web portal users 
of and the formation by means of a web portal of the 
composition of a contest committee and designation of 
the secretary of a contest committee;
- the publication of the announcement of carrying 
out the competition on a web portal;
- receiving by potential suppliers – participants 
of a web portal of competitive documentation with 
automatic registration of the fact of its receiving on a 
web portal;
- an explanation by means of a web portal of 
provisions of competitive documentation to the 
potential suppliers who received it in the cases 
provided by the points 50, 51, 52, 53 and 54 of the 
Rules;
- the registration on a web portal of the applications 
for participation in competition submitted in the form 
of the electronic document;
- the opening of demands and the publication on a 
web portal of the relevant protocol of the opening;
- the consideration by a contest committee of 
electronic applications for participation in competition 
for designation of the potential suppliers conforming to 
qualification requirements, requirements of competitive 
documentation;
- the designation by a contest committee of the 
list of the potential suppliers who are not conforming 
to qualification requirements and requirements of 
competitive documentation, their informing by means 
of a web portal with the indication of the reasons of 
discrepancy. Also the contest committee can carry out 
request of the missing documents or additional data 
necessary for reduction of the demands of potential 
suppliers for participation in the competition according 
to qualification requirements and requirements of 
competitive documentation. The publication of the 
results of this designation is carried out in working 
hours on time of Astana on a web portal in the relevant 
ORGANIZATION AND EXECUTION OF ELECTRONIC 
GOVERNMENT PROCUREMENTS OF GOODS, WORKS,  
SERVICES WHICH ARE CARRIED OUT BY THE UNIFORM 
ORGANIZER IN THE WAY OF COMPETITION

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146
protocol of the preliminary 
admission to participation in the 
competition;
- automatic registration on 
a web portal of the applications 
for participation in competition 
provided by potential suppliers 
according to qualification 
requirements and requirements 
of competitive documentation 
submitted in the form of the 
electronic document;
- the designation by the 
contest committee by means of a 
web portal of the list of potential 
suppliers who are allowed to 
participate in the competition and 
the size of conditional discounts. 
The publication of the results of 
this designation is carried out in 
working hours on time of Astana 
on a web portal in the protocol 
on the admission to participation 
in the competition. The organizer 
of government procurements at 
the publication of the protocol of 
the admission places information 
on the exact date and time of the 
beginning of the reception of price 
offers on a web portal. Thus, the 
beginning of the reception of price 
offers should be not earlier than 
one day from the moment of the 
publication of the protocol of the 
admission;
- the designation by a contest 
committee of the best technical 
specification (or specifications) 
of goods, services presented 
by potential suppliers in the 
application for participation in the 
competition with the account - at 
their existence – of opinions of 
experts commission or the involved 
expert. The publication of the 
results of this designation is carried 
out on a web portal in the protocol 
on the admission to participation in 
the competition;
- the automatic registration on 
a web portal of the competitive 
price offers presented by potential 
suppliers, allowed to participation 
in the competition in the form of 
electronic documents;
- the automatic opening, 
assessment, comparison of 
competitive price proposals of the  
competition participants and the 
designation of the winner by the 
web portal;
- the automatic publication of 
the protocol on competition results 
on the web portal;
- following the results of 
competition - the conclusion 
between the customer and the 
winner of the competition of 
the contract on government 
procurements.
At the organization of a 
competition for government 
procurements of the goods, works, 
services which are not uniform the 
uniform organizer can organize 
and carry out uniform government 
procurements in the specified 
way with division of such goods, 
works, services in competitive 
documentation on lots by their 
uniform types.
At the implementation of 
a competition on government 
procurements of uniform goods, 
works, services, the uniform 
organizer in competitive 
documentation divides uniform 
goods, works, services into lots 
by the place of their delivery 
(performance, rendering).
At the implementation of 
a competition on government 
procurements of several types of 
uniform goods, works, services, the 
uniform organizer in competitive 
documentation divides goods, 
works, services into lots by their 
uniform types and (or) in a place 
of their delivery (performance, 
rendering).
1) demand of a customer 
for carrying out electronic 
government procurements of 
goods, works, services in the way 
of competition 
2) technical specification. 
In the cases provided by the 
legislation of the Republic 
of Kazakhstan, the technical 
specification should be agreed 
with the appropriate authorized 
body
3) decision on designation of 
the composition of experts 
commission or an expert
4) draft agreement on 
government procurements.
THE TASK OF A CUSTOMER SHOULD 
CONSIST OF THE FOLLOWING DOCUMENTS:
NOTE:
 
The specified documents should be approved by the first head or the 
responsible secretary or other official who is exercising powers of the 
responsible secretary of the customer or the person acting as the first head 
of the customer.

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147
Murat SEYTAKHMETOV,
head of the FGC KGZ MF RK
The committee on government procurements 
of the RK Ministry of Finance, according to point 
4 of article 11 of the RK Law «About Government 
Procurements» (further - the Law), carries out 
claim-related work about the recognition of 
the potential suppliers as unfair participants of 
government procurements.
The main reason for submission of statements 
of claim in court, according to article 11, point 4, 
subparagraph 2, of of the Law, is finding of potential 
suppliers in the Unified register of debtors on executive 
productions of the Ministry of Justice of the Republic of 
Kazakhstan (further – the Register of debtors).
For example, from 32 claims for the recognition 
as an unfair participant of government procurements 
submitted during work of the Committee in 25 cases 
(78%) the basis of submission of the claim was finding of 
the potential supplier in the Register of debtors.
The deadline for filing a statement of claim by a 
customer, or an organizer, according to article 11 of 
the Law, is thirty calendar days from the date when he/
she knew of the fact of violation of the legislation of the 
Republic of Kazakhstan on government procurements by 
the potential supplier or supplier.
  The reasons for filing a statement of claim about 
the recognition as an unfair participant of government 
procurements are following:
1) the representation of unreliable information 
according to qualification requirements by potential 
suppliers;
2) the violation of requirements of article 6 of the Law 
by potential suppliers;
3) the evasion from the conclusion of a contract 
on government procurements by potential suppliers 
determined by winners;
4) non-execution or inadequate execution by 
suppliers of the obligations under the contracts on 
government procurements signed with them.
Practice of maintaining the register of unfair 
participants of government procurements corresponds 
to the best international experience and is a barrier to 
decrease risks of plunder and inefficient use of budgetary 
funds.
Actually reasons of filing a statement of claim 
given above can serve as criteria of an assessment of a 
potential supplier’s reputation, that is at their absence it 
is possible to speak about sufficient degree of probability 
of the contract appropriate execution. 
For example, according to a article 6 of the Model 
law of UNCITRAL about purchases of goods (works) 
and services (adoppted in New York 31.05.1994 - 
17.06.1994 at the 27th session of UNCITRAL), a potential 
supplier should possess necessary professional and 
technical qualification data, professional and technical 
competence, financial resources, equipment and other 
material resources, administrative competence, reliability, 
experience and reputation, and also human resources for 
performance of contract on purchases. 
Thus, the reputation of a potential supplier is an 
obligatory selection criterion when using budgetary 
funds.
This rule also found the reflection in the Contract on 
the Eurasian Economic Union signed by the Republic of 
Kazakhstan. 
So, according to the point 13 of the Protocol on the 
order of purchases regulation (the appendix 25 to the 
CLAIM-RELATED WORK ABOUT THE 
RECOGNITION AS AN UNFAIR PARTICIPANT 
OF GOVERNMENT PROCUREMENTS

қараша | ноябрь | november № 11 (23)
148
Contract on EEU), the legislation of the member state 
on purchases should provide formation and maintaining 
the register of unfair suppliers which joins in which the 
following data should be included:
about potential suppliers who evaded from the 
conclusion of agreements (contracts) on purchases;
about suppliers who didn’t fulfill or inadequately 
fulfilled the obligations under the agreements (contracts) 
on purchases signed with them;
about suppliers with whom customers unilaterally 
dissolved agreemnts (contracts) on purchases in the 
course of execution of which it is established that 
the supplier doesn’t conform to the requirements to 
potential suppliers established by documentation about 
purchase or provided unreliable information about the 
compliance to such requirements that allowed it to 
become the winner of procedure of purchase by the 
results of which such contract is signed.
Distinctive feature of the current law «About 
government procurements» and Contracts on EEU is that 
the international treaty does not provide inclusion in the 
register of unfair suppliers of the persons who are not the 
winners of competitions or the party of the contract, that 
is potential suppliers.
In this regard, in the developed Ministry of Finance of 
the RK the bill «About Government Procurements» (in the 
new edition), planned to introduction since 01.01.2016, 
the standards of the international treaty, providing that 
measures for inclusion in the register of unfair suppliers 
will not be applied to potential suppliers, are considered, 
but at the same time the mechanism interfering their 
participation in government procurements before 
elimination of the available violations is kept. 
Free circulation of goods, works and services in the 
territory of the EEU also sets for the governments of 
member states tasks to establish mechanisms which will 
not admit the participation of unfair suppliers from the 
EEU countries, which will identify them and carry out 
work on their inclusion in the register.
The solution of these tasks will cause further 
synchronization of the legislation of member states, 
adjustment of channels of information exchange, 
including the integration of information systems and 
recognition of digital signatures, and also perhaps in the 
long term – creation of united registers in the sphere of 
government procurements for the EEU countries.
I ask to make an explanation on a situation. The 
company signed the contract for rendering services in 
August, 2011. The customer, according to the contract, 
paid advance payment. During the currency of the 
contract additional agreements on extension of terms 
were signed. At the moment acts of the performed works 
are not signed, these liabilities the performer recognizes 
as doubtful. 
The income from doubtful liabilities, according to 
subitem 3 of item 1 of Art. 88 of RK Tax Code, includes 
write-off of liabilities in connection with expiry of the 
statute of limitations as established by the legislative 
acts of the Republic of Kazakhstan . According to item 2 
of Art. 88 of RK Tax Code, An amount of income received 
as a result of writing off liabilities shall be equal to the 
amount of liabilities, subject to repayment in accordance 
with source documents of the taxpayer. According to 
item 1 of Art. 178 of RK Civil Code,  the general term of 
the statute of limitations shall be established at three 
years.  According to item 2 of Art. 180 of RK Civil Code, 
with regard to the liabilities which have a definite term 
for their implementation, the course of the statute of 
limitations shall begin upon the expiry of the date of the 
execution. 
Question No. 1: Since what moment does the term 
of the statute of limitations on the received advance 
payments which were not demanded within three years 
start being estimated for recognition of the income from 
doubtful liabilities: 
– from the moment of signing of the contract;
 – from the moment of receiving advance payment;
– from the moment of the termination of the 
additional agreement on extension of terms?
Question No. 2: Are received advance payments 
recognized as doubtful requirements considered as 
assessed turnover of the VAT?
Concerning the first question … We pay attention that the 
income from doubtful liabilities is determined according to Art. 
89 of the Tax code. 
So, subitem 4) of item 2 of Art. 89 of the Tax Code established 
that the income from doubtful liabilities not specified in 
subparagraphs 1) – 3) of this paragraph shall be recognized in 
the tax period of the expiry of the three year period: 
From the day following the day of expiration of the period 
for fulfillment of the liability with respect to the acquired goods 
(works, services) for which the fulfillment period has been 
defined; 
From the day of transfer of goods, performance of works, 
provision of services with respect to the liability connected with 
the acquired goods (works, services), for which no fulfillment 
period has been defined. 
Concerning the second question … According to the 
Tax Code existing in edition for January 1, 2011, the received 
advance payments are not considered as turnover assessed by 
the VAT.
COMPETENT ANSWER

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150
Zhanna ABDRAKHMANOVA,  
deputy head of managements of appeals and
providing of legitimate rights of the SRC of the 
MF RK
Now in system of the pre-judicial appeal 
the State Revenue Committee of the Ministry 
of Finance of the Republic of Kazakhstan 
is engaged in consideration of taxpayers 
complaints concerning results of tax audit on 
confirmation of reliability of the VAT excess 
sums shown to return from the budget.
In 9 months of 2015 the Committee considered 
38 such complaints.
Thus, as shows the analysis, the most often 
appealed questions are non-confirmation of 
reliability of the VAT excess sum shown to return by 
results of counter checks, and also non-confirmation 
of such sum as a result of application of a control 
system of risks.
We will draw on the specified questions.
Often taxpayers appeal results of check regarding 
refusal in return of the VAT excess because at the 
time of the end of check replies to the requests on 
carrying out cross audits are not received or such 
inquiries were stopped by territorial tax authority. 
It should be noted that the order of carrying out 
topical audits of reliability of the VAT excess sum 
shown to return is regulated by Article 635 of the Tax 
code.
According to item 5 of Art. 635 of the Tax code, 
during topical audit the tax service authority may 
prescribe cross audits of direct suppliers of goods, 
work, services of the auditee taxpayer. 
At this item 9 of Art. 635 of the Tax code cases 
no refund of value-added tax shall be made within 
amounts for which no response is received by the 
date of completion of the tax audit: to the requests 
for conducting a cross audit for confirmation of 
accuracy of settlements with the supplier.
Thus, the Tax code contains direct norm that at 
non receipt before completion of check of replies to 
the requests on carrying out cross checks reliability of 
such sums of the VAT is not confirmed. 
Respectively, at the appeal the decision on such 
complaints is made by taxpayers of the specified 
question, proceeding from the given standard 
of the Tax code, that is at confirmation during 
consideration of the complaint of the fact of non 
receipt before completion of check of replies to 
the requests on carrying out cross checks reliability 
of the VAT sums by results of consideration of the 
complaint is also not confirmed.
At the same time according to subitem 1) item 
10 of Art. 635 of the Tax code refund of value-added 
tax shall be carried out on the basis of the report on 
tax audit when receiving responses to requests for 
conducting cross audits of suppliers of the auditee 
Hello, I am going to be granted a status of a 
disabled person in August. I would like to specify, 
whether there are tax and other privileges for 
disabled people, and what documents need to 
be handed over and in what terms? Thank you in 
advance.
Income in limits of 55 monthly salary is not subject 
to taxation by individual income tax, it also concerns 
disabled people of I, II, III groups.
According to subitem 5) of item 3 of Art. 365 of the 
Tax Code, disabled people are not taxpayers with regard 
for owned side-cars and cars – in respect of one motor 
transport vehicle which is an taxable item for tax.
According to subitem 4) of item 3 of Art. 373 of the Tax 
Code, disabled, and also one of the parents of a disabled 
person from childhood, orphaned children and children 
deprived of parental care up to the age of eighteen years 
shall not be recognized as payers of land tax  in respect of: 
land plots occupied with housing resources, in 
particular buildings and structures attached to them; 
land plots attached to houses; 
land plots allotted for keeping personal household 
(subsidiary) farms, gardens and dacha construction, in 
particular lands occupied with buildings; 
land plots occupied with garages.
According to subitem 3) item 2 of Art. 403 of the Tax 
Code payers of the property tax of natural persons are 
not disabled of the I and II groups – within a 1500-time 
amount of the monthly assessment index established 
by the Law on the republican budget and effective as 
of 1st January of the corresponding financial year, of the 
total value of all taxable items they hold on the right of 
ownership.
I am asking to consult me on the  taxation of 
the CIT and VAT of realization of the empty land 
plot (without constructions) with the purpose – to 
construct oil depot with limited liability partnership 
(the generally established mode) to other limited 
liability partnership. The land plot was got without 
the VAT. Will the VAT of  transaction be assessed or 
can we apply Art. 249 as on the earth anything is 
constructed? If the income is bared, how to write 
out the invoice?
Realization of the land plot is exempted from the VAT, 
according to item 2 of Art. 249 of the Tax Code, thus the 
size of a turnover of realization is defined according to 
item 9 of Art. 238 of the Tax Code. 
For calculation of CIT according to subitem 1) item 1 of 
Art. 87 of the Tax Code at realization of the land plot arises 
the income from an increase in value which is defined as 
a positive difference between the cost of realization and 
initial cost.
COMPETENT ANSWER

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151
APPEAL OF TAX AUDIT RESULTS: 
SOME QUESTIONS ON RETURN OF THE VAT 
taxpayer, which are received after completing the 
tax audit. Thus, such conclusion of tax authority is 
formed not earlier than the twentieth and no later 
than the twenty fifth day of the last month of the 
quarter. 
Thus, in the considered situation in case of 
receipt of replies to the requests on carrying out 
cross checks after completion of topical audit to the 
taxpayer return of the VAT excess according to the 
specified standard of the Tax code is carried out on 
the basis of the conclusion of tax authority, that is 
without carrying out audit.
Also one of the most often appealed questions 
is the VAT non-return in connection with the 
termination by territorial tax authorities of requests 
for carrying out cross checks of suppliers.
As shows the analysis of the considered 
complaints, the termination of requests for carrying 
out cross checks by tax authorities is carried out in 
most cases because of absence of the supplier in the 
location. Thus, such absence is confirmed by the act 
of tax inspection which procedure is regulated by 
article 558 of the Tax code.
Thus, according to item 9 of Art. 635 of the Tax 
code one of the bases for a non-return of the VAT is 
non-confirmation of reliability of the sums of the VAT 
in connection with impossibility of carrying out cross 
check, including because of absence of the supplier 
in the location.
Thus, the matter is also accurately regulated 
by standards of the Tax code in this connection in 
case of confirmation of the fact of not carrying out 
cross check because of absence of the supplier in 
the location during consideration of the complaint, 
reliability of the sums of the VAT by results of 
consideration of the complaint is also not confirmed.
At the same time according to item 2 of Art. 273 
of the Tax code the value-added tax payer shall have 
the right to refund of excess value-added tax, which 
has formed after January 1, 2009, during the period 
of the statute of limitations as established by Article 
46 of this Code. 
In this regard the taxpayer to whom it is refused 
to return the excess of the VAT, including because 
of not carrying out cross check in view of absence 
of the supplier in the location has a right to submit 
again during the term of limitation period the 
requirement about return of the VAT. Thus, the tax 
authority will carry out topical tax audit by results 
of which in case of confirmation of reliability of the 
sums of the VAT return of the VAT will be carried out. 
One more of the most often appealed questions 
is non-confirmation of the sum of excess of the VAT 
shown to return as a result of application of a control 
system of risks.
As shows the analysis which is carried out by 
results of consideration of complaints, one of 
the questions which are most often appealed by 
taxpayers in this block is the question of illegal 
formation of the analytical report «Pyramid» on the 
suppliers included in the list of taxpayers on whom 
the tax authority stops further formation of the 
analytical report.  
It should be noted that the control system of risks 
(further – the CSR) is regulated by Art. 625 of the 
Tax code according to item 2 of which probability 
of non-execution and (or) incomplete execution of 
the tax obligation by the taxpayer (tax agent) which 
could admit and (or) can cause damage to the state 
can be considered as a risk. 
According to item 4 of the specified article, 
the CSR is used at implementation of tax control, 
including for the purpose of confirmation of the VAT 

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152
excess sum which is subject to return.
By the same article it is provided that criteria 
of degree of risk and the order of application of a 
control system of risks for confirmation of the VAT 
excess sum shown to return are defined by the 
Government of the Republic of Kazakhstan.
In this regard the resolution of the Government 
of the Republic of Kazakhstan of March 27, 2013 
No. 279 approved Rules of application of a control 
system of risks for confirmation of the VAT excess 
sum, shown to return (further – the Rules).
According to item 8 of the Rules concerning 
the taxpayers referred to category of the taxpayers 
who are in a risk zone, the tax authority forms the 
analytical report «A pyramid on suppliers» (further 
– the analytical report «Pyramid») on suppliers of 
goods, works, services.
At this item 9 of the Rules it is established a list 
of taxpayers for whose suppliers tax authority stops 
further formation of the analytical report «Pyramid». 
These are the following taxpayers:
1) being monitored by large taxpayers;
2) making goods of own production, including 
agricultural producers-taxpayers (except for 
producers of flour, woolfell of large and small cattle 
and the persons processing scrap of non-ferrous and 
ferrous metals);
3) carrying out activity within the contract for 
subsurface use;
4) carrying out delivery of electric and thermal 
energy, water and (or) gas, except for electric 
and thermal energy, water and (or) gas which are 
exported further by their buyer;
5) carrying out delivery of communication 
services;
6) carrying out delivery of services in technical 
tests, analysis and certification of production.
Thus, the Rules contain direct norms regulating 
cases of the termination of further formation of the 
analytical report «Pyramid».
At the same time, as it appears from the 
considered complaints, separate checking at 
implementation of check of reliability of the VAT 
excess sum shown to return for suppliers of the 
above-stated taxpayers further formation of the 
analytical report «Pyramid» is made.
Considering that the matter is accurately 
regulated by the tax law, by consideration of such 
complaints, in case of confirmation of the fact that 
taxpayers are from the category of the taxpayers 
included in the above list, audit results about non-
confirmation of reliability of the VAT regarding the 
matter admit are illegal.
Also it would be desirable to draw on a direction 
of requests for elimination of the violations revealed 
as a result of formation of the analytical report 
«Pyramid» by the tax authority which is carrying out 
topical  audit.
The Rules show that inquiries are sent for 
elimination of violations in case of identification 
of violations of the tax law concerning taxpayers – 
suppliers of the subsequent levels on whom such 
violations are revealed by the results of formation of 
the analytical report «Pyramid». 
Respectively, in case such supplier of the 
subsequent level is the taxpayer monitored by large 
taxpayers, the inquiry concerning this taxpayer is 
also sent for elimination of violations.
At the same time the matter is challenged by 
some taxpayers who consider that concerning the 
large taxpayers who are subject to monitoring, cross 
check according to provisions of Art. 635 of the Tax 
code, should not be carried out.
In fact, according to item 7 of Art. 635 of the Tax 
code a certain category of suppliers of the checked 
payer of the VAT, including major taxpayers who 
are subject to monitoring is not subject to counter 
check.
Subparagraph 3) point 5 of article 627 of the 
Tax code gave definition of cross audit as an audit 
carried out by the tax authority in relation to persons 
who carry out transactions with a taxpayer (tax 
agent) in relation to which the tax authority carries 
out an integrated or topical audit persons for the 
purpose of obtaining additional information on such 
transactions for use in the course of auditing of said 
taxpayer. 
It follows from this norm that a counter 
inspection is carried out only concerning the direct 
supplier (the supplier of the first level) by whom 
operations with the checked taxpayer were carried 
out. 
However, in the case under consideration it is 
about major taxpayers – suppliers of the subsequent 
(the 2nd, 3rd, 4th etc.) levels whose violations of the 
tax law are established as a result of formation of 
the analytical report «Pyramid». Besides, as shows 
the analysis, concerning such suppliers during audit 
not inquiries for carrying out cross audits were sent, 
but requests for elimination of violations provided 
by item 10 of the Rules that fully corresponds to the 
order established by the tax law. 
In this regard at the appeal of similar questions 
by taxpayers the decision is made in favor of 
conclusions of tax audit. 
In summary it would be desirable to note that 
by consideration of the complaint of taxpayers 
about a tax audit results regarding refusal in return 
of the shown of the VAT excess sum by the relevant 
division of State Revenue Committee carefully 
checks and investigates the arguments and 
circumstances which were the basis for refusal in 
return of the VAT from tax authority, and arguments 
and circumstances on which the taxpayer who 
made the complaint bases the requirements and 
proofs. Thus, the maximum efforts for ensuring 
objectivity and transparency in consideration of 
complaints are made.

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RAIMBEK COMPANY  – 
NATIONAL CHAMPION
“OUR MAIN ADVANTAGE IS 
EFFECTIVE MANAGEMENT”
The history of the Kazakhstani 
Raimbek Company began in 1992 
with creation of small trading 
company which delivered consumer 
electronics from Singapore, Japan, 
Italy, Switzerland and Hong Kong.
Today the Raimbek Company is a 
large, successfully developing holding 
company focused mainly on food 
production and retail trade.
The Raimbek group companies 
traditionally occupy the leading 
positions in the Kazakhstani market. 
In particular, the share of Raimbek 
Bottlers in the market of juices and 
beverages in cardboard package 
makes up 32%, the share of the 
Raimbek Agro in the market of ultra-
heat-treated milk makes up 23%, the 
share of “Raimbek Alco” in the market 
of imported alcohol makes up 30%.
In May 2015 the companies of the 
Raimbek Holding entered the pool 
of “national champions” within the 
framework of the state program on 
supporting Kazakhstan’s business. 
We offer you a series of interviews 
with top managers of one of the most 
successful companies of Kazakhstan.
- What attracts you to working in the Raimbek 
Company?
- You know, I’m not used to be complacent, and the 
work in our company is the constant drive, all the time 
there are new projects, fresh solutions. In addition, there are 
managerial ambitions - I just have to finish what I’ve once 
begun: it was originally a small project and then there were 
establishment and automation of business processes, and 
then the operational management. Economic instability 
has given a new challenge: not merely to survive times of 
crisis, but to improve efficiency, to show shareholders that 
the company has qualitatively changed. We are working for 
the future; both develop a current business and work on the 
diversification of risks due to new projects.
- But isn’t it rather difficult to implement new projects 
in times of crisis?
- Yes, it’s not easy. Therefore, we come very punctually 
and carefully to the choice of new growth points. Now we try 
to manage with small investments. This September we launch 
a dairy project: buy PET line and produce kefir and yoghurt 
drinks under our major milk brand “Ainalayin”.
- How will you characterize the global competitiveness 
of the Raimbek Сompany?
- First of all, extensiveness. Raimbek is the first such a 
company in the Kazakhstani market. Initially, our company’s 
share content made up to 80% of milk and juices. Of course, 
with the appearance and development of competitors we 
lost positions somehow, but we still remain one of the major 
leading companies in Kazakhstan.
The second point is that we have the best distribution 
network in the country. It is recognized by all major 
companies in the world, with whom we are working. For 
example, our share in the market of juices makes up 95%. We 
also have an active customer base in the market of milk. In 
addition, we have a high level of distributors.
And the third is that we have learned how to proactively 
monitor the expenditure of the company and become more 
Reference:
Vitaly Borkov joined the Raimbek Company in 2003. 
Qualified as a financier, he started from the position of project 
manager, later became a COO of the dairy plant; since 2013 he 
is CEO of the companies of FMCG division. He is keen on sports, 
nearly 13 years of his life he used to be involved in boxing.
Vitaly BORKOV, 
CEO, Food division 
of the Raimbek Company 

қараша | ноябрь | november № 11 (23)
154
efficient in terms of cost management. Today our efficiency is 
higher, and the costs are lower than the industry average.
- What results of your work can you be proud of?
- We have significantly improved our efficiency. This is 
seen primarily in the financial results. That is, even in a falling 
market if we fall, it is much less than our competitors do.
Actually, I want to say that even in a crisis, we have been 
able not only to stay in the market, but also to increase profits 
due to the internal optimization and clear and tight control 
over all expenditures. That is, we were able to knock down 
in the crisis. We have introduced the project management in 
the company. This immediately affected the overall efficiency 
- the speed of decision-making on launching new projects 
significantly increased, this process became more transparent 
and predictable.
Now I have a period of active immersion into the details 
of operational management, improvement of the sales and 
marketing setting. In the future, I hope, I will reach personnel 
management system, so far, for me this is the biggest 
unrealized challenge.
- What are you planning to do?
- In the near future, we have to finalize the HR-strategy 
and actively engage in the creation of a team of associates: 
the directors and middle managers. So all our employees 
understand where we are going, and feel a sense of 
belonging to the result.
And the most important task is, of course, increasing sales, 
especially because the market situation is not the easiest. Of 
course, we are planning to focus on exports. We intend to 
bring to the market of the neighboring countries our new 
products. Let’s see what happens.
“I LIKE TO TAKE 
RESPONSIBILTY”
In August 2015 the Raimbek Company’s products appeared on the shelves of the large Russian network “Dixie”. This 
business achievement can be rightly considered as the merit of the commercial department of the food division.
- Denis, are you also responsible for export of 
Raimbek products?
- Yes. In my competence there are export, distribution 
in Kazakhstan, work with new foreign partners. Now we are 
actively working on expanding our presence in Russia.
In August, we have reached one of the largest networks 
of Moscow and Russia “Dixie” with “Juicy” juices. It is about 2 
thousand stores of the network, today it is 60% of the market 
share. Also, our products will be presented in the Perm region 
- it’s plus 400 stores. In addition to “Juicy” juices in the future in 
Russian stores there will be our new dairy brands, which now 
have no analogues in the dairy market.
- How did you manage to come to the Russian 
network? Everyone is talking that due to the exchange 
rate difference Kazakhstan’s products are less 
competitive.
- You know, if it were not for bad luck have no luck at all. 
Ukrainian companies have gone from the Russian networks 
and released shelves. We have just taken a moment: we have 
offered our goods in time. Yes, we realize that our prices 
are above average, but our Juicy juice is positioned in the 
premium segment, so there are no any problems.
 - What, in your opinion, are the advantages of the 
Raimbek Company as a ocal Kazakhstan’s company? 
Why are you stronger than international and 
transnational corporations?
- Our most important advantage is that we are fighting for 
our own national brands, while they are fighting for someone’s 
else. We have a sense of ownership. I feel it among our 
employees, subordinates and try to implement it throughout 
the company.
- What is the Raimbek Company’s sales policy?
- We have been working through distributors. We have 
a partner in each city, through which we implement sales. 
Regional representatives are our employees. Every year their 
number increases.
Reference: 
Denis Postrigan has two higher educations: military 
engineering and law. Started trading career in 2005 as an 
assistant to trade representative. Since 2010 he has been 
working in the Raimbek Company - first as regional director, 
and then as the commercial director.
Denis POSTRIGAN, 
Commercial Director, 
Food Division of the Raimbek Company 

қараша | ноябрь | november № 11 (23)
155
Now we are slightly changing work scheme when 
distributors perform only the role of logistics operators and 
sales representatives and supervisors become employees 
of the Raimbek Company. We have such a work scheme in 
Western Kazakhstan, in the next year we are planning to move 
to such a work system throughout Kazakhstan.
First of all this is due to the fact that a sense of the value 
of work in a large national company for people is much more 
than the work in local, regional, city firm. This factor acts as a 
motivation, when people realize that they are the part of a 
great unity - national leading company.
- You have been working in the Raimbek Company 
for 5 years, what has been the most difficult?
- Each company, as well as a person, is individual. The style 
of the Raimbek Company’s is multitasking for a limited period 
of time. In other words - all must be done now and fast! (smiles) 
Gradually I have used to this. Now I do not understand how I 
have used to live at a different pace.
- What are your professional accomplishments you 
are proud of?
- I am very proud of my team. For five years of the work in 
the company just a few left my department. I understand that 
I am going the right way: choose the right people, who follow 
me and who like to work together. Accordingly, the work 
becomes more efficient.
I am glad that the Raimbek Company gave me the 
opportunity of independent decision-making. I like to take 
responsibility and make decisions and every day decision-
making level is getting higher, and decisions are more and 
more. That’s what motivates me personally.
Hello! I am an individual entrepreneur, who 


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