Transfer Pricing

Transfer pricing ("TP") rules have existed in Kazakhstan for more than 20 years. During this period, Kazakhstan’s tax authorities have performed numerous TP audits many of which resulted in disputes ultimately resolved in court.

Recently, attention to TP has grown worldwide, both from authorities and businesses, including within the framework for implementation of the initiatives developed by OECD for fighting base erosion and profit shifting (BEPS). Kazakhstan is no exception and implemented new types of TP reports. Nevertheless, revision of the Kazakhstan TP rules to bringing them in line with the best international practice is under consideration.

Along with the historic focus in Kazakhstan on export of resource commodities, increasing attention is paid to TP issues concerning financial transactions, purchase of services, import of consumer and industrial goods and licensing of intangibles.

We have assembled an extremely strong TP team consisting of local and international experts covering Kazakhstan and Eurasian Region and various industries. 

Contact us and we will provide you with comprehensive TP support. More information about the TP rules in Kazakhstan and assistance we offer is presented in our brochure.

Our Services

Preparation of monitoring reports, Local File, CbCR and Master File
Preparation / localization / update of transfer pricing documentation for all types of transactions
Preparation of benchmarking studies for prices, profitability margins, interest rates, royalty
Development of transfer pricing policies and procedures
Diagnostics of transfer pricing risks
Assistance with transfer pricing matters ad-hoc
Train in-house specialists

Our strength

Our team has successful experience in supporting the appeal of TP tax audits

We provide services to clients in all major sectors of the economy

Comprehensive support for TP

The team consists of local and international experts and covers Kazakhstan and the Eurasian region

High quality services

Annually more than 130 projects

Paid seminars

Seminar topic: Transfer pricing for taxpayers.

Date: 21-22 July, 2022

Day 1:

  1. Fundamentals and principles of transfer pricing
  2. Current trends and review of court practice
  3. Key expected legislative changes

Day 2:

  1. Preparation of the notification and local file for the TP
  2. Preparation of benchmark studies
  3. Impact of current economic situation on transfer pricing

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Contacts

Michael Ahern

Partner, Tax, Legal and People, Almaty, PwC Kazakhstan

+7 727 330 3200

Email

Elena Kaeva

TLP Leader, Almaty, PwC Kazakhstan

+7 727 330 3200

Email

Timur Zhursunov

Partner, Tax, Legal and People Services, Almaty, PwC Kazakhstan

+7 727 330 3200

Email

Nursultan Nurbayev

Director, Transfer Pricing, Almaty, PwC Kazakhstan

+7 701 953 3535

Email

Elvira Haliulina

Manager, Transfer Pricing Services, PwC Kazakhstan

+7 727 330 3200

Email

Inkar Yessimova

Manager, Transfer Pricing Services, PwC Kazakhstan

+7 727 330 3200

Email

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