Overview of Transfer Pricing rules in Kazakhstan

Relations arising from transfer pricing (TP) between taxpayers and government agencies in Kazakhstan are similar to the principles of OECD Guidelines, and are regulated by local legislation, that is, the Law of the Republic of Kazakhstan “On Transfer Pricing” dated 5 July 2008.

More detailed information on TP rules in Kazakhstan is presented here, and is divided into four sections:

1. Implementation of controls and what the Kazakhstan tax authorities expect from taxpayers.
2. Price controls as part of transaction monitoring.
3. Price controls as part of three-tiered reporting.
4. Changes to TP from 2026.