TRANSFER PRICING

On 1 January 2026, important changes to transfer pricing regulation came into force in the Republic of Kazakhstan. Law of the Republic of Kazakhstan No. 215-VIII of 18 July 2025 introduced key amendments to the Law "On Transfer Pricing," and the new Tax Code of the Republic of Kazakhstan (Law No. 214-VIII) changed the tax architecture directly affecting transfer pricing. The State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan is rapidly digitalizing control: the ISNA, KEDEN, and Smart Data Finance systems consolidate data from various sources and form a digital profile of the taxpayer. The statute of limitations for large taxpayers has been extended to 5 years, and new enforcement measures include suspension of electronic invoice (ESF) issuance and restrictions on the departure of executives from the country.

Deadlines for submitting controlled transaction monitoring reports for 2026 are approaching. Submission of the report often entails the need to provide documentation on controlled transactions – now within a shortened 30-day period. The deadline is approaching for submitting country-by-country reporting (Form 012 MO) for the 2025 reporting period, taking into account the changes coming into force on 1 January 2027.

Objective of the seminar – to examine the innovations of the Law "On Transfer Pricing" and Kazakhstan's tax reform, discuss the State Revenue Committee's tax control practice in the context of digitalization, provide recommendations on preparing documentation and minimizing risks, and analyze reporting errors and strategic approaches to pricing in the changed regulatory environment.

The seminar is intended for specialists of transfer pricing departments and planning and economic departments, heads of legal departments, tax lawyers, taxation specialists, financial directors and chief accountants of enterprises, and persons who are controlling persons in groups of companies.

PROGRAM:

• International taxation and information exchange in 2026. Innovations in the transfer pricing legislation of the Republic of Kazakhstan. Law of the Republic of Kazakhstan No. 215-VIII of 18 July 2025: key amendments to the Law "On Transfer Pricing." Double taxation avoidance agreements: Kazakhstan's interaction with countries that have suspended their DTTs with Russia. Practical implications for Kazakhstani companies working with counterparties from such countries. Interest, dividends, royalties: application of DTTs and tax conventions under current conditions. International exchange of financial information: Kazakhstan's participation in the CRS, the effectiveness of automatic exchange. The structure of financial data flows in Kazakhstan and beyond. Trends and changes in international taxation – experts' forecasts for 2026 and beyond.
• Building transfer pricing processes in the company and their automation. Combinations of transfer pricing methods. Softening the rigid hierarchy of methods (Article 12 of the Law "On Transfer Pricing"): selecting the method that most accurately reflects the economic substance of the transaction. Recommendations on modifying and applying transfer pricing methods to substantiate transactions. Selected issues of documenting the pricing methodology. A workshop on applying the comparable profitability method using popular services and databases.
• The risk-free interest rate, intangible assets, and the expanded concept of related parties. Legislative enshrinement of the risk-free interest rate for the tenge (the National Bank of Kazakhstan's base rate), the euro (EURIBOR), the US dollar (SOFR), and other currencies. Practical implications for analyzing intra-group loans: which risks are accounted for in the rate, how to calculate the credit risk premium, and how to substantiate it documentary. Case studies on intra-group financial transactions. The concept of an "intangible asset" in the new transfer pricing legislation: an identifiable non-monetary intellectual property object. Reallocation of risk under transactions with intangibles to the party that actually controls it and has the financial capacity to assume it. Practical approaches to analyzing transactions with intangibles: license payments, royalties, technology transfer.
• Expansion of the list of related parties: direct inclusion of spouses. New criteria for related-party status and their practical application. Assessing the impact of the expansion on the structure of groups of companies and the risk of transactions being classified as controlled.
• The State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan's approaches to transfer pricing tax administration in 2026-2027. Subjects of transfer pricing tax control. Scenarios for organizing supply chains and stabilizing financial flows with foreign counterparties. Changes in the operation of international holding structures and the tax component of acquiring direct ownership of economically significant companies.
• Digitalization of tax control: the Smart Data Finance system and a single "data lake" from various sources. ISNA, KEDEN – reducing the number of information systems from 14 to 5. The taxpayer's digital profile for risk assessment. The plan for transforming the State Revenue Committee into a "fiscal data factory." Automatic tracking and refinement of risk criteria for tax violations in transfer pricing.
• Evolution of transfer pricing rules. Overview of innovations and reporting changes. Overview of transfer pricing provisions within Kazakhstan's tax reform and the Main Directions of Tax Policy of the State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan for 2026–2027. New forms of transaction monitoring reporting (Order of the Minister of Finance of the Republic of Kazakhstan No. 782 of 17 December 2025). Practical recommendations on completing the new forms. Notification of controlled transactions. Transfer pricing documentation: additional information to be disclosed. Country lists: Kazakhstani lists of offshore and low-tax jurisdictions compiled by the State Revenue Committee of the Ministry of Finance of the Republic of Kazakhstan. Practice of working under periodically updated lists. Issues in analyzing transactions with companies from countries included in the list. Changes in the scope and depth of analysis.
• Expansion of the perimeter of controlled transactions. New controllability criteria and their application. Practical implications for companies conducting operations with goods included in the expanded list. Criteria for controllability of transactions under Article 3 of the Law "On Transfer Pricing." Strategy for preparing documentation on transactions with independent parties. Assessing potential risks and revising pricing approaches in connection with the expansion of the perimeter. Opportunities for concluding advance pricing agreements (APAs) with the State Revenue Committee: procedure, practice, and status of the instrument.
• Liability for violating transfer pricing rules: additional assessments, fines, criminal liability. Evolution of liability in the new Tax Code of the Republic of Kazakhstan. New enforcement measures. Criminal liability: thresholds under the Criminal Code of the Republic of Kazakhstan. Recognition of transfer pricing adjustment amounts as dividends in transactions with foreign related counterparties. Individual and subsidiary liability of individuals.
• Transfer pricing practice: tax control, inspections, disputes. Transfer pricing control as a tool against tax evasion. Burden of proof of the arm's length nature of prices in intra-group transactions. Overview of typical structures and methods of defending them by taxpayers. Practice of transfer pricing tax inspections in Kazakhstan: what attracts the attention of the State Revenue Committee; whether an inspection can be avoided by providing explanations and documents; how an inspection is conducted; whether its results can be challenged. Analysis of State Revenue Committee cases on transactions, spreads, and quotation periods.
• Relocation of Russian business to Kazakhstan and transfer pricing risks: artificial intermediary structures, profit shifting, qualification of transactions. How the State Revenue Committee views transfer pricing as a key channel for withdrawing the taxable base. BEPS 2.0 and Kazakhstan's position: the global minimum tax of 15% (Pillar Two): how are BEPS principles applied? International information exchange and practical recommendations for business under current conditions.

ONLINE PARTICIPATION COST: 95,000 tenge

REGISTRATION on www.seminar.com.kz;

or call +7 717 264 05 42; +7 717 264 05 93

E-mail: conference@seminar.com.kz