Transfer pricing in Kazakhstan: taxpayer obligations in 2025

To which transactions do transfer pricing rules apply?

• Applies to international business transactions — transactions between a resident of Kazakhstan and a non-resident, or transactions between residents outside Kazakhstan;
• It also applies to domestic transactions if they are directly related to international activities, if:
  • The transaction is related to a subsoil use contract;
  • One of the parties to the transaction enjoys tax preferences; or
  • One of the parties has incurred losses in the two years preceding the year of the transaction.

What do tax authorities do?

• Monitor transfer pricing transactions by observing the prices applied by transaction participants;
• Conduct checks in case of price deviations from market prices — comparative analysis, document requests, adjustment of the tax base using market median prices and profitability;

What should taxpayers do?

• Identify applicable transactions — transactions with non-residents, transactions within Kazakhstan but related to international operations, etc.
• Prepare and submit reports, including:
  • Local reporting (for each individual company); – submitted within 12 months following the reporting financial year (deadline for 2024 – by December 31, 2025) while meeting the following criteria:
    • The total amount of controlled transactions with related parties exceeds 250,000 MCI for the reporting year;
    • Revenue for the year preceding the reporting financial year exceeds 5 million MCI.
  • The main reporting (group reporting within the Republic of Kazakhstan) is submitted at the request of the tax authorities within 30 calendar days from the date of receipt of the request;
  • Country-by-Country report (if the group is transnational) – submitted at the request of the tax authorities within 12 months from the date of receipt of the request;
  • Application for participation in the international group – submitted no later than September 1 of the year following the reporting financial year (deadline for 2024 – September 1, 2025);

• Regularly update transfer pricing documentation.

Transaction monitoring

Monitoring reports are submitted for international business transactions according to the list, the total amount of which exceeds 250 thousand MCI for the reporting year. The list includes, among other things, goods such as oil, petroleum products, certain metals, as well as construction and installation works, marketing and forwarding services, and, starting in 2025, financial and other types of transactions.

Documentation on TP

Tax authorities have the right to request transfer pricing documentation for any transaction subject to transfer pricing control, regardless of the interconnection between the parties to the transaction. The request may be made retrospectively within a three-year limitation period. However, the Tax Code of the Republic of Kazakhstan provides for an extension of the period to five years if the taxpayer falls into one of the following categories:

• Large business entity;
• Operates in accordance with a subsoil use contract;
• Resident of the Republic of Kazakhstan owning a controlled foreign company (CFC);
• Individual who applied for standard deductions for lump-sum pension payments (LSP) after the date of withholding of personal income tax (PIT) in respect of the relevant income.

Documentation on transfer pricing must be provided within 30 calendar days from the date of receipt of the request.

How can we help you?

Our experts are ready to support you in all necessary actions related to transfer pricing reporting and preparation for tax audits. Please see below for information about our services and offers.

• Identification of related parties and controlled transactions;
• Review of the company’s activities, analysis of commercial and financial terms of controlled transactions. Selection of an appropriate transfer pricing analysis method;
• Comparative transfer pricing analysis;
• Preparation of transfer pricing documentation;
• Updating transfer pricing documentation;
• Preparing/adapting master file documentation;
• Preparing local file documentation;
• Preparing a statement of participation in an international group.