On 16 March 2022, the State Revenue Committee announced that they opened a public consultation on a draft bill to amend transfer pricing rules. The deadline for this public comments is 8 April 2022. The draft Bill contained the following measures that would:
- improve the requirements for three-level reporting documentation in compliance with the recommendations of the OECD base erosion and profit shifting (BEPS) project.
- eliminate the transfer pricing control exemption for commodity exchange where the destination market is outside Kazakhstan in order to reduce the risk of selling resources abroad at reduced prices.
- make an expansion of the definition of related party.
- apply an interquartile range mechanism to control the market price. And
- improve current transfer pricing methods hierarchy to bring flexibility in determining the best method for determining the market price.
