The amendment proposes using the official exchange rate to calculate the CbC reporting threshold under transfer pricing rules.
Kazakhstan’s Ministry of Finance has initiated a public consultation regarding the draft order proposing changes to the transfer pricing (TP) law.
The proposed amendments focus on the calculation method for the EUR 750 million threshold that determines the obligation for Country-by-Country (CbC) reporting and the submission of the Master File by multinational enterprise (MNE) group members operating in Kazakhstan.
Currently, the threshold is converted using the arithmetic average market exchange rate. The proposed change would require the use of the official exchange rate set by the National Bank of Kazakhstan instead. This adjustment aims to provide greater legal certainty and consistency in the application of exchange rates for determining reporting obligations.
The consultation is set to conclude on 21 July 2025.