The Minister of Finance in late 2018 approved forms and procedures for filing the Master files and Local files, with the guidelines being effective 1 January 2019.
In general, the rules for Master file and Local file are consistent with the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations; however, there is a distinction for the Local file in Kazakhstan in that it covers only transactions between members of a multinational group that are subject to transfer pricing control in Kazakhstan.
A government decree in 2018 amended the procedures for concluding an advance pricing agreement (APA) between the appropriate government official of Kazakhstan and a domestic taxpayer. Under the amendments, the State Revenue Committee of the Ministry of Finance is authorized as the official body to act on behalf of the government to enter into APAs and replaces the prior authorized body.
Also, the decree reduced the period allowed for consideration of an APA application from 90 days to 60 days (as measured from the date of receipt of the APA application).
Read a January 2019 report [PDF 773 KB] prepared by the KPMG member firm in Kazakhstan
© 2019 KPMG International Cooperative (“KPMG International”), a Swiss entity. Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm. All rights reserved.
Member firms of the KPMG network of independent firms are affiliated with KPMG International. KPMG International provides no client services. No member firm has any authority to obligate or bind KPMG International or any other member firm vis-à-vis third parties, nor does KPMG International have any such authority to obligate or bind any member firm.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.