Transfer pricing in Kazakhstan

Elimination of transfer pricing risks:

Advise on transfer pricing under the Organization for Economic Cooperation and Development (OECD) transfer pricing concept
Assist in preparation of transfer pricing documentation
Assist in updating transfer pricing documentation

Transfer pricing requirements in Kazakhstan

Companies concluding transactions with related foreign entities (so-called controlled transactions) must submit documents to tax authorities for verification of the prices applied in such transactions. If such prices are not in line with market level, this could indicate an understatement of payable taxes. Below we described all the requirements, deadlines and our transfer pricing services.

Penalties for understated tax

If it is found during a tax audit that the tax base was understated because transfer prices were not in line with market prices, tax authorities will then be entitled to collect unpaid taxes, as well as impose a penalty

Penalty is 40% on the unpaid tax amount

Preparation of 3-tiered transfer pricing documentation

Services for the preparation of a three-tier transfer pricing documentation on the Organization for Economic Cooperation and Development (OECD) transfer pricing concept:

Global documentation (Master file);
National documentation (Local file);
Country-by-country reporting.

Elimination of transfer pricing risks

Companies are not subject to fines if they submit transfer pricing documentation.
We offer full support for preparation of transfer pricing documentation and for tax audit preparation.

Our transfer pricing services

Identification of related entities and controlled transactions;
Business overview and selection of appropriate transfer pricing method;
Comparative analysis of transfer prices, including market analysis and calculation of corporate indicators;
Preparation and updating of transfer pricing documentation;
Preparation of report on controlled transactions.

Our experts in transfer pricing

All our specialists have extensive experience in tax consultation, transfer pricing analysis and preparation of documentation according to international standards developed by the OECD.