On 30 October 2026, the State Revenue Committee (SRC) published updated methodological guidance on transfer pricing compliance, addressing documentation requirements, comparable selection criteria, and advance pricing agreement (APA) procedures for multinational enterprises (MNEs) operating in Kazakhstan. The guidance clarifies the application of the arm’s length principle in line with OECD Transfer Pricing Guidelines and the latest BEPS Action 13 recommendations. It introduces standardized templates for master file and local file preparation, defines materiality thresholds for controlled transactions, and outlines the process for bilateral and multilateral APAs.
Key Takeaways
- Enhanced Documentation Standards: Taxpayers must now submit master file and local file within 12 months of fiscal year-end, with penalties for non-compliance increased to 5% of transaction value.
- Comparability Analysis: The guidance mandates the use of regional comparables where available and requires explicit justification for any deviations from standard benchmarking methodologies.
- APA Program Expansion: The SRC encourages MNEs to utilize the APA program for certainty, offering streamlined procedures for renewals and rollbacks up to three prior years.
Disclaimer: This article is compiled and summarized by the AI based on publicly available information and is for general information purposes only. It does not constitute any form of formal tax advice, legal opinion, or basis for performance. Please consult a qualified professional tax advisor or legal counsel for tax advice.
Source: Read Official Announcement