Three-tiered transfer pricing documentation in Kazakhstan

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

  • Master file
  • Local file
  • Country-by-country report (CbCR)
Request offer

Master file

A general description of the group’s activities should be provided in the master file as follows:

  • Description of the group structure and control within it;
  • Description of the markets in which the companies of the group operate;
  • Description of the group’s activities;
  • Description of the group’s intangible assets;
  • Description of the group’s financial activity.

Tax authorities are entitled to request the group master file from companies that are part of an international group.

Local file

The local file should provide, as listed below, detailed information about intragroup transactions in which a company is involved:

  • Structure of the company’s management bodies;
  • Description of the company’s activities and of its market strategy;
  • Description and functional analysis of intragroup transactions in which the company is involved;
  • Justification of transfer price compliance with market prices.

Country-by-country report (CbCR)

The country-by-country report provides a summary of all the participants (companies) in an international group of companies and contains the following information:

  • Global distribution of income within the group;
  • Taxes paid in various jurisdictions in which the group is represented.

Companies must submit country-by-country reports if they are the parent company of the group or the company within the group authorized to submit this report on behalf of the group.

Companies must also submit CbCRs as and when requested by tax authorities.

Leading positions

Konsu is one of the leading consulting companies in Russia. We have been included in the following ratings of the rating agency Expert RA:

  • Top-10 in accounting outsourcing
  • Top-10 in payroll outsourcing
  • Top-15 in financial consulting
  • Top-15 in legal consulting

Our services

We have extensive experience in advising companies with foreign participation as well as with transfer pricing analysis and preparation of transfer pricing documentation according to OECD guidelines and the tax law. We would be pleased to:

  • Review the situation of your company and provide recommendations for compliance with legal requirements
  • Assist with reporting forms and liaise with group companies on documentation issues related to the preparation of:
    • Master file;
    • Local file;
    • Country-by-country report.