Kazakhstan strengthens transfer pricing control

Kazakhstan strengthens transfer pricing control

Kazakhstan is set to enhance control over export transactions. The Mazhilis, a Lower House of the Kazakh Parliament, approved on first reading amendments on the transfer pricing. The implementation of the draft law will prevent the loss of state revenue in international business operations. The document aims at improving the application of the five methods for determining market value. For example, if taxpayers opt for only one method, they are required to justify the reason for not applying the others. It is also proposed to narrow the market range to establish more equitable pricing. Additionally, there are provisions to enhance control measures for capital outflows from the country, involving an expanded definition of interrelated parties. It is worth noting that the OECD has endorsed the bill, taking into account the nature of international transactions and the economic features of the country.

“The draft law also proposes monitoring transfer pricing of transactions conducted on commodity exchanges. Currently, there is no control over transfer pricing for transactions carried out on the country’s commodity exchanges. Such transactions frequently occur at prices below market rates, creating the opportunity for capital outflow from the country. Therefore, it is proposed to eliminate the above-mentioned provision from the law,” said Kazakh Deputy Prime Minister and Finance Minister Yerulan Zhamaubayev.