Business
Update re Kazakhstan withholding tax disputes
Nostrum Oil & Gas PLC has provided an update on withholding tax disputes involving its subsidiary Zhaikmunai LLP and the Kazakhstan tax authorities, noting that a decision from the Ministry of Finance Appeal Board has been postponed. The Appeal Board is considering communications from the Dutch tax authority under a mutual agreement procedure, which may lead to a suspension of the appeal pending its outcome. The company maintains that the tax claims for 2018, 2019, and 2020, which relate to exemptions on bond interest, intra-group loan remuneration, and consulting services income, are without merit. Nostrum Oil & Gas PLC continues to monitor the situation and will defend its interests. Disclaimer*
About this update from Nostrum Oil & Gas Plc
[{"type":"text","content":"\n\nNOT FOR RELEASE, PUBLICATION OR DISTRIBUTION, IN WHOLE OR IN PART, IN, INTO OR FROM ANY JURISDICTION WHERE TO DO SO WOULD CONSTITUTE A VIOLATION OF THE RELEVANT LAWS OF THAT JURISDICTION\n \nFOR IMMEDIATE RELEASE\n \n \nLondon, 9 February 2026\n \n \nFurther update regarding Kazakhstan withholding tax disputes\n \nNostrum Oil & Gas PLC (LSE: NOG) (the \"Company\" and together with its subsidiaries, the \"Group\"), an independent oil and gas company engaging in the production, development and exploration of oil and gas in the pre-Caspian Basin of Western Kazakhstan, provides a further update on withholding tax disputes involving its principal operating subsidiary, Zhaikmunai LLP (\"ZKM\") and the tax authorities in the Republic of Kazakhstan (\"RoK\"), following on from its announcement on 3 February 2026.\nAt a hearing on 6 February 2026 regarding ZKM's challenge to tax claims by the RoK tax authorities resulting from their tax audits of ZKM for the years 2018 and 2019, the RoK Ministry of Finance Appeal Board (the \"Appeal Board\") postponed its decision. ZKM understands that the Appeal Board is reviewing and considering communications from the Dutch tax authority pursuant to the mutual agreement procedure (\"MAP\") under the relevant double tax treaty between the Kingdom of the Netherlands and the RoK (the \"RoK-NL Treaty\") in respect of the pertinent claims, which may result in the suspension of the appeal pending the outcome of the MAP.\nParagraph 3 of Article 4 of the RoK Constitution provides that international treaties ratified by the RoK (such as the RoK-NL Treaty) have priority over RoK domestic laws (including the RoK tax code) and RoK Supreme Court precedent provides that where an international treaty contains a mutual agreement procedure such as the MAP, for the good faith performance of the treaty such mutual agreement procedure, when invoked, should be conducted between the competent authorities of the two states party to the treaty to achieve the goals of such treaty. A treaty party may not invoke the provisions of its internal law as justification for a failure to perform its treaty obligations.\nAs previously announced, the Company believes that the tax claims made by the RoK tax authorities resulting from their tax au...