Kazakhstan: Amendments to transfer pricing framework
Effective January 1, 2026
Kazakhstan enacted Law No. 215-VIII on July 18, 2025, amending the transfer pricing regime effective January 1, 2026.
Key changes include:
- Analyzing controlled transactions involving intellectual-property rights based on actual conduct and risk profile
- Converting the €750 million country-by-country (CbC) report threshold to KZT using the National Bank's rate
- Legislating a baseline risk-free rate for various currencies
- Defining intangible assets for transfer pricing purposes
- Requiring transfer pricing documentation within 30 days of a request
For more information, contact a KPMG tax professional in Kazakhstan:
Gaukhar Mukasheva | gmukasheva@kpmg.kz