Transfer pricing establishes a fair value for intra-group transactions. It helps ensure tax compliance and transparency in cross-border operations.
Transfer Pricing
Understand the value. Align the strategy. Comply with confidence.
Transfer pricing (TP) legislation has existed in Kazakhstan for nearly 25 years. During this period, substantial law enforcement practices and extensive judicial precedents have been developed regarding the application of transfer pricing control and the determination of conditions that may lead to relevant tax adjustments.
"At PwC Kazakhstan, we have built one of the strongest TP teams in the market, ready to provide comprehensive support on all TP matters and interactions with tax authorities. Our team also has access to extensive market price databases."
Alongside the historical focus on the export of raw materials, Kazakhstan's tax authorities are also paying attention to transfer pricing issues related to financial transactions, the purchase of services, the import of consumer and industrial goods, licensing of intangible assets, and other controlled transactions.
The tax authorities actively conduct TP audits, including by collecting information provided by taxpayers in:
- local, master, and country-by-country (CbC) reports (the so-called three-tiered documentation developed as part of the OECD BEPS initiative);
- transactions monitoring reports;
- TP documentation and other data submitted upon request of the tax authorities.
Accordingly, taxpayers are expected to timely identify the scope of their controlled transactions and determine arm’s length pricing for them.
Our services
Consulting on transfer pricing matters
Transfer pricing risks assessment
Development of transfer pricing policies and proceduresсделок
Trainings for in-house specialist
Preparation of transfer pricing documentation, including country-by-country reports, master file, local file, and monitoring report
Preparation/ localisation / update of transfer pricing documentation for all types of transactions
Preparation of benchmarking studies for prices, profitability margins, interest rates, royalty
Support during transfer pricing audits
Appeal of transfer pricing audit results
Support during application procedures for advance pricing agreements (APAs)
Transfer Pricing
For more information about TP rules in Kazakhstan and how we can support your business, please refer to our brochure
Contact us
Запросите коммерческое предложение или задайте вопрос PwC.
Contacts
Elena Kaeva
Timur Zhursunov
Nursultan Nurbayev
Elvira Haliulina
Aigerim Tursyn
Ailana Bexultanova
