Kazakhstan will enforce higher penalties for non-compliance with Country-by-Country (CbC) notification requirements from 13 March 2025.

Large taxpayers will face fines of KZT 1,966,000, while medium-sized enterprises will be penalised KZT 983,000 for failing to file, or submitting incomplete or inaccurate notifications.

CbC notifications, required for MNE group participation, must be submitted by 1 September following the reporting fiscal year. The monthly calculation index (MCI) for 2025 is set at KZT 3,932.

CbC Reporting is a minimum standard formulated by the Organisation for Economic Co-operation and Development (OECD) under Action 13 of the Base Erosion and Profit Shifting (BEPS) Package.

Under this standard, a multinational enterprise group (MNE Group) must file a CbC Report for an accounting period if the consolidated group revenue for the preceding period is at least EUR 750 million and the group has constituent entities or operations in two or more jurisdictions.

The CbC Report requires aggregate tax jurisdiction-wide information relating to the global allocation of the income, the taxes paid, and certain indicators of the location of economic activity among tax jurisdictions in which the MNE Group operates.

The Report also requires a listing of all the constituent entities for which financial information is reported, including the jurisdiction of incorporation of each of the constituent entities (if different from the tax jurisdiction of residence) and the main business activities carried out by that entity.

CbC Reports are to be exchanged automatically between tax administrations under relevant exchange arrangements.