According to the legislation of the Republic of Kazakhstan on transfer pricing, participants of multinational enterprises (MNEs) are required to submit an Notification about Participation in MNE to the authorized body.
The deadline for submitting the Notification for 2024 is September 1, 2025.
An MNE is a group of entities, including the parent company of the group, that simultaneously meet the following conditions:
- the group of entities includes at least one person who is recognized as a resident of the Republic of Kazakhstan or is not recognized as a resident of the Republic of Kazakhstan but carries out entrepreneurial activities in the Republic of Kazakhstan through a structural subdivision or permanent establishment;
- are related to each other through control and/or participation;
- consolidated financial statements are prepared for them, or their financial statements are not taken into account when preparing consolidated financial statements solely due to the size or materiality of such persons in accordance with international financial reporting standards or other internationally recognized standards for the preparation of financial statements, accepted by stock exchanges for the admission of securities to trading
Please note that the consolidated turnover of the group is not a criterion for determining the need for Kazakhstani members of the group to submit Applications.
Failure by a member of the group to submit an application for participation in the group or submission by such a member of the group to the authorized body of an application containing inaccurate information shall entail liability in accordance with the laws of the Republic of Kazakhstan.
We are ready to offer our services in preparing Applications for participation in the MG, as well as other consulting services on transfer pricing issues.
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