Kazakhstan: Transfer pricing documentation includes CbC | KPMG Global
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Kazakhstan: Transfer pricing documentation includes country-by-country reporting

Kazakhstan: Transfer pricing documentation includes CbC

New measures in Kazakhstan establish the criteria for certain entities of multinational enterprises (MNEs) operating in Kazakhstan to follow and rules for filing with the tax authorities certain transfer pricing documentation—including a notification of being a member of the MNE, a Local file, a Master file, and a country-by-country (CbC) report.


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The new provisions include applicable definitions of terms and filing requirements.

  • The new transfer pricing filing requirements for MNEs are being phased in, with the reporting year for the CbC report being 2016 (that is, a retroactive effective date). 
  • The first reporting year or period for the Local file and Master file is 2019.
  • The first deadline for the notification requirement is 1 September 2018, for those members of MNEs that meet the requirements for filing CbC reports.


Read a 2018 report [PDF 295 KB] prepared by the KPMG member firm in Kazakhstan

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