Kazakhstan Transfer Pricing Documentation Requirements
Kazakhstan treats the Local File and broader transfer pricing documentation as genuinely separate obligations. A Master File and Local File apply to large groups above revenue and materiality thresholds, while transfer pricing documentation can be requested from taxpayers below them. Penalties are set in minimum calculation index units geared to entity size.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Member of an MNE group with consolidated revenue > EUR 750m | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 30 days. | KK / RU | Yes (250 MCI medium / 500 MCI large entities) |
Local File Required | Standalone revenue > 5,000,000 MCI in the prior year and material categories of controlled transactions | By the Local File deadline | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 90 days. | KK / RU | Yes (250 MCI medium / 500 MCI large entities) |
TP documentation Required | Requestable from taxpayers below the Local File threshold and for non-material transactions | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 90 days. | KK / RU | Yes (250 MCI medium / 500 MCI large entities) |
CbC report Required | Group revenue ≥ EUR 750m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
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Scope of the documentation obligation
The Master File applies to entities belonging to multinational groups with consolidated revenue above EUR 750 million. The obligation to prepare a Local File arises where two conditions are met together: the standalone revenue of the Kazakh taxpayer for the year preceding the reporting year exceeds 5,000,000 minimum calculation index units, a figure updated annually, and the taxpayer conducted material categories of controlled transactions. Distinct from these, transfer pricing documentation can be requested from taxpayers below the Local File threshold, for non-material related-party transactions, and in certain other situations, so the Local File and the broader documentation are separate legal concepts rather than tiers of one.
Distinctive features of the Kazakh regime
The defining feature of the Kazakh regime is precisely that separation between the formal Local File and the requestable transfer pricing documentation, which can apply to taxpayers and transactions the Local File does not reach. The penalty structure is expressed in minimum calculation index units and graded by entity size, at 250 units for medium-sized entities and 500 units for large entities, so the consequence scales with the taxpayer rather than the transaction. Kazakhstan also operates targeted safe harbours, including a 10 percent price deviation tolerance for transactions in agricultural goods and approved methodologies for specific transactions. A transfer pricing monitoring report is filed annually by 15 May.
Benchmarking and comparables
The choice between local and foreign comparables is not specified. A multi-year analysis covering the three years preceding the reporting year should be conducted. The frequency of a fresh search is not specified. The general limitation period for tax purposes is three years after the end of the relevant period, capable of extension to seven years in certain transfer pricing cases.
Frequently asked questions
How do the Local File and transfer pricing documentation differ in Kazakhstan?
The Local File is a formal document for taxpayers meeting the revenue and materiality thresholds, while transfer pricing documentation can be requested separately from taxpayers below that threshold and for non-material transactions, making them distinct obligations rather than tiers of one.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.