Transfer Pricing


Transfer pricing ("TP") rules have existed in Kazakhstan for more than 15 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 the framework for implementation of the initiatives developed by OECD for fighting base erosion and profit shifting (BEPS). Kazakhstan is no exception. 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 covering Kazakhstan and wider Eurasia. Team members have Kazakhstan and foreign experience. We work with different clients across various industries, typically addressing questions such as:

  • Whether the Kazakhstan TP rules apply to transactions of the company concerned?
  • What are the TP requirements you need to comply with?
  • How to structure your international operations from a TP perspective?
  • How to identify TP risks and mitigate them; how to prepare TP documentation and a TP policy; how to design an internal function for dealing with TP?
  • How to prepare for a TP audit?
  • In case of an ongoing TP audit or TP dispute, what are the options to defend your position and to establish a dialogue with the tax authorities? Our long-term relationships with the tax authorities are extremely helpful in this context.

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.

Contact us

Michael Ahern

Partner, Leader of Tax & Legal Services, PwC Kazakhstan

Тел.: +7 727 330 3200

Adel Sapargaliyeva

Senior Manager, Tax & Legal services, PwC Kazakhstan

Тел.: +7 727 330 32 00
+7 707 221 55 77

Nursultan Nurbayev

Senior Manager, Legal services, PwC Kazakhstan

Тел.: +7 717 255 0707

Follow us