Kazakhstan: Amendments to transfer pricing framework

Effective January 1, 2026

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November 10, 2025

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

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