Understanding Transfer Pricing Rules and Support
in Kazakhstan ​​

In Kazakhstan, transfer pricing control applies to specific categories of transactions, including international operations and related domestic transactions.

• International Business Transactions (IBT):
  • transactions in which one party to the transaction is a non-resident not registered in the RoK, and the other party to the transaction is a resident of the RoK or a non-resident operating in the RoK through a permanent establishment;
  • transactions of residents made outside the territory of the Republic of Kazakhstan. 
• transactions made in the territory of the Republic of Kazakhstan, directly related to the IBT, i.e. transactions, the subject of which is the subject of the IBT if one of the following criteria is met:
  • the sale of minerals extracted by the subsoil user, which is one of the parties, takes place;
  • one of the parties has tax benefits;
  • one of the parties has a loss according to tax returns for the last two tax periods preceding the year of the transaction;
  • parties to the transaction have different corporate income tax rates.

Members of international groups operating in Kazakhstan are required, under certain conditions, to submit  TP documentation to the tax authorities.

The TP documentation is structured into three tiers, each with specific reporting requirements:

• Country-by-Country Notification – filed no later than 1 September of the year following the reporting financial year (for FY2024 by 1 September 2025);​
• Country-by-Country Reporting - filed upon request of tax authorities within 12 months from the request date;​
• Master file - filed upon request within 30 calendar days from the request date;​
• Local file - filed annually within 12 months following the reporting financial year if the following conditions are met simultaneously: ​
• Turnover of controlled transactions with related parties exceeds 250 thousand MCI for the reporting year; ​
• Revenue for the year preceding the reporting financial year exceeds 5 million MCI.

Monitoring reporting​

Monitoring reporting must be submitted for international business transactions listed in the List* if the annual transaction turnover exceeds 250,000 MCI. The list among other items includes oil, petroleum products, certain metals, construction and installation works, marketing and forwarding services, and from 2025 - financial transactions. The monitoring report submitted by May 15 of the year following the reporting financial year (for FY2024 by 15 May 2025).​

*The Order of the Minister of Finance of the Republic of Kazakhstan dated 19 March 2015 No. 194.​

TP documentation​

TP documentation may be requested by the tax authorities for any transaction subject to control under the TP Law, regardless of whether the transaction is carried out with related or independent parties.

The tax authorities are entitled to request this documentation retrospectively, within a statute of limitations of five years. The TP Documentation should be provided within 30 calendar days following the request.

We provide the following services:

• Compliance with the TP Law:​
• Preparation / localization / updating of CbCR, Master files, Local files, monitoring and TP documentation reports, CbCR Notifications; ​
• Preparation of benchmarking studies for prices, profitability (margins), remuneration rates on loans, royalties.​

TP consulting:​

• Consulting on TP matters;​
• Diagnostics of TP risks; ​
• Development of policies and procedures related to TP; ​
• Training of specialists on TP issues.

Planning and transformation:​

• Structuring a business for tax efficiency;​
• Allocation of taxable profits between the head office and a permanent establishment.​

Position defense and dispute resolution: ​

• Support during tax audits and reconciliation of positions with tax authorities;​
• Preparation of appeals against notification / statements to the court and representation of your interests in the Ministry of Finance of the Republic of Kazakhstan and in all judicial instances;​
• Assistance in concluding advance pricing agreements, as well as during the mutual agreement procedure.