Kazakhstan has revised the MNE group participation notification or country-by-country (CbC) notification form through Order No. 84 of 24 February 2025.
The Order No. 84 amends Order No. 178 of 14 February 2018, which includes adjustments to the form and requires electronic submission with a digital signature.
Paper submissions are allowed only if electronic submission is not possible, in which case an electronic copy is also required. If the deadline falls on a non-working day, it is postponed to the next working day.
The submission deadline remains 1 September of the year after the reporting fiscal year.
Earlier, Kazakhstan announced that it will increase penalties for non-compliance with CbC notification rules starting 13 March 2025. Large taxpayers face fines of KZT 1,966,000, while medium-sized businesses will be fined KZT 983,000 for missing, incomplete, or incorrect notifications.
Under BEPS Action 13, all large multinational enterprises (MNEs) are required to prepare a country-by-country (CbC) report with aggregate data on the global allocation of income, profit, taxes paid and economic activity among tax jurisdictions in which they operate. This CbC report is shared with tax administrations in these jurisdictions, for use in high level transfer pricing and BEPS risk assessments.
