Olga Vorobyeva, General Director EMG KZ

Olga Vorobyeva has been the head of the legal practice at Emerging Markets Group since 2009, bringing over 20 years of experience in the field of law.

Olga graduated from Saint Petersburg State University, Faculty of Law. She completed the School of Tax Attorneys and is an active member of the Chamber of Tax Consultants, where she trains specialized professionals and corporate employees. Olga is an expert in tax law, including international taxation, regulation of cross-border transactions, and tax planning. Her clients include subsidiaries, branches, and representative offices of multinational corporations in the logistics, freight transportation, export, and software development industries.

Public Activities and Teaching:
• Co-Chair of the Finance Committee at the St. Petersburg International Business Association (SPIBA).
• Member and Lecturer of the Russian Federation Chamber of Tax Consultants.
• Lecturer of the Course "International Tax Law and Taxation" at the International Business School of the Financial University under the Government of the Russian Federation.

Olga has been actively participating in professional events as a speaker, lecturer, and moderator for over 10 years. Her deep expertise in law and tax legislation allows her to collaborate effectively with accountants and auditors, offering innovative solutions for financial departments.
Olga Vorobyeva is a recognized professional in tax law with extensive experience working with international companies. Her active engagement in educational and public activities makes her a valuable member of the professional community.

• Saint Petersburg State University, Faculty of Law;
• Saint Petersburg State University, Advanced Training, School of Tax Attorneys;
• Center for Additional Educational Programs of Saint Petersburg State University, advanced training under the program “Tax Consulting”.

• General Director, EMG KZ (2023 – present)
• Head of Legal Department. Senior Tax Consultant, EMG (2009 – present)
• Senior Lawyer, EMG (2006 – 2016)
• In-house Lawyer, Bioline Group of Companies (2003 – 2006)

Taxation of International Transportation
Advised on taxation of cross-border transportation involving foreign entities, with a focus on Kazakhstan tax law and double tax treaties.
Scope of work:

• analysis of payment flows and roles of parties;
• determination of tax agent obligations in Kazakhstan;
• assessment of treaty benefits and tax exemptions;
• identification of withholding tax risks.

Result: clear and practical tax model ensuring compliance with Kazakhstan tax regulations and minimizing exposure.

Intra-group Debt Restructuring
Advised on restructuring intercompany debt involving a foreign parent company, taking into account Kazakhstan tax and currency regulations.
Scope of work:

• development of restructuring strategy;
• tax impact analysis of available options;
• structuring compliant solutions under Kazakhstan law.

Result: debt obligations settled with minimal tax impact and full regulatory compliance.

Tax Structuring of Share Transactions
Advised on a share sale involving a foreign investor with a focus on Kazakhstan tax implications.
Scope of work:

• analysis of tax consequences for both parties;
• review of related-party and pricing risks;
• assessment of non-resident taxation in Kazakhstan;
• transaction structuring.

Result: tax-efficient and compliant deal structure with reduced risk of reassessment.

Business Fragmentation Risk Assessment
Advised a group of companies in the hospitality sector on tax risks under Kazakhstan anti-fragmentation approaches.
Scope of work:

• review of group structure and operations;
• tax risk assessment;
• estimation of potential tax exposure;
• restructuring recommendations.

Result: clear risk visibility and actionable mitigation strategy.

Real Estate Tax Optimisation
Advised on reducing tax burden for a commercial real estate owner in Kazakhstan.
Scope of work:

• analysis of available tax incentives;
• assessment of special regimes and statuses;
• tax savings calculation;
• implementation roadmap.

Result: identified sustainable tax optimisation mechanisms under Kazakhstan law.

Structuring Business Presence in Kazakhstan (Branch Setup)
Advised a Russian aviation services company on establishing and operating its business in Kazakhstan while providing aircraft maintenance services in Almaty.
The project focused on assessing permanent establishment risks and determining the most efficient form of presence in Kazakhstan.
Scope of work:

• analysis of actual activities (personnel, premises, duration) for permanent establishment risk;
• assessment of tax implications of operating without local registration;
• recommendation and structuring of an optimal model — branch establishment;
• detailed guidance on tax and currency regulation, including corporate taxation and branch profit taxation;
• practical roadmap for registration and ongoing compliance.

Result: the client received a clear and compliant market entry strategy with a sustainable tax and operational model in Kazakhstan.