On 24 December 2018, Mr. Alikhan Smailov, the Finance Minister of Kazakhstan approved forms and procedures for filling the Master files and Local files, effective from January 01, 2019.
Generally, the rules for Master file and Local file are in line with the OECD Transfer Pricing (TP) Guidelines for Multinational Enterprises and Tax Administrations. Major difference of the Local File from is that it covers only transaction between members of a multinational group which are subject to transfer pricing control in Kazakhstan.
On 8 September 2018, the Government Decree amended a procedure for concluding an Advance Pricing Agreement (APA) between State Revenue Committee of the Ministry of Finance and a local taxpayer. According to the amendments, the State Revenue Committee is authorized as the official body to act on behalf of the government to enter into APAs and replaces the prior authorized body.
Additionally, the Decree reduced the term for consideration of applications for APA from 90 to 60 business days from the date of receipt of application.
