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Kazakhstan: Transfer pricing documentation; APA procedures

Kazakhstan transfer pricing documentation

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.


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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.

APA procedures

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

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