Kazakhstan

Background

The Transfer Pricing regulations in Kazakhstan are regulated by Law № 67-IV “On Transfer Pricing, dated July 05, 2008.

Related Parties

Transfer pricing regulations apply to all cross-border transactions and certain transactions domestically, regardless of the relationship between the parties.

Transfer Pricing Methods

The five traditional methods are as follows:

Comparable Uncontrolled Price Method.
Resale Price Method.
Cost Plus Method.
Profit Split Method.
Transactional Net Margin Method.

Transfer Pricing Documentation

Notification of Shareholding in a Multinational Company

The parent company of a multinational group, authorized member of an international group (if the Transfer Pricing reports are filed by an authorized member of an international group), as well as members of an international group performing business activities in Kazakhstan (if obliged to file at least one of the three-tier documents in Kazakhstan), must file a notification on the shareholding in the multinational group no later than September 1 of the year following the reporting fiscal year.

Local Report

The requirements for preparing and filing a local report apply to a member of a multinational group that, in the reporting fiscal year, performed transactions under the control of the Transfer Pricing regulations (i.e., international business transactions or related transactions) and whose income, according to its financial information for the fiscal year preceding the reporting fiscal year, is at least KZ Tenge 13.89 thousand million.

Master File

According to the Transfer Pricing Act, a member of the multinational group files the Master File to the authorized body at its request in the reporting fiscal year no later than 12 months from the day on which the member of the international group receives a request for such a report.

The requirements for preparing and filing the Master File also apply to a member of a multinational enterprise that, in the reporting fiscal year, performed transactions under the control of the Transfer Pricing regulations in Kazakhstan, with the amount of income in the consolidated financial statements of the enterprise for the fiscal year immediately preceding the reporting fiscal year is at least € 750 million or other amount established by the legislation of the foreign state, whose resident is the parent company of the international group.

Master File

The requirements for preparing and filing the Master File also apply to a member of a multinational enterprise that, in the reporting fiscal year, performed transactions under the control of the Transfer Pricing regulations in Kazakhstan, with the amount of income in the consolidated financial statements of the enterprise for the fiscal year immediately preceding the reporting fiscal year is at least € 750 million or other amount established by the legislation of the foreign state, the resident of which is the parent company of the international group.

Country-by-Country Reporting

The Country-by-Country reporting requirements apply to the parent company of the multinational enterprise (resident of the Republic of Kazakhstan) or an authorized member of an international group (if the parent company of an international group has granted such member the authority to file Country-by-Country reports, or another member of an international group entrusted with the obligation to file Country-by-Country reports at the request of the authorized body if the amount of revenues of the consolidated financial statements of the multinational group for the fiscal year immediately preceding the reporting fiscal year is at least € 750 million or other amount established by the legislation of a foreign state, the resident of which is the parent company of the international group.

Penalties

Fines for non-compliance with the reporting requirements may range from € 1,450 to € 2,900.

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