Transfer pricing

Transfer pricing remains one of the most complex and closely scrutinized areas of taxation for multinational enterprises. Globally, tax authorities are increasingly focused on ensuring that cross-border transactions reflect arm’s length principles and that profits are appropriately allocated across jurisdictions. This scrutiny often extends to arrangements involving intellectual property, intercompany financing, and centralized procurement or marketing functions.

In Kazakhstan, the transfer pricing regulatory landscape is continuously evolving, with frequent legislative updates that expand reporting obligations and redefine the scope of transactions subject to compliance. These changes highlight the importance for businesses operating in or with Kazakhstan to stay current and ensure their transfer pricing policies and documentation meet the latest transfer pricing requirements. Our capabilities include:

Advisory on transfer pricing compliance and risk areas
Development and review of transfer pricing policies
Preparation of transfer pricing documentation (master file, local file, country-by-country report)
Functional and economic analysis, including benchmarking studies
Structuring and analysis of controlled transactions
Support with business restructuring documentation and economic substance alignment
Review of intercompany agreements (e.g., cost-sharing, service, and IP arrangements)
Value chain analysis to support pricing rationale
Assistance during tax authority audits
Guidance on Advance Pricing Arrangements (APA) where applicable