Article 17-1. The procedure for determining the range of prices and the range of profitability (margin) Transfer Pricing Law

      1. In order to apply the methods specified in subitems 1), 2), 3) and 5) of paragraph 1 of Article 12 of this Law, unless otherwise provided for in Article 13 of this Law, a range of prices and (or) a range of profitability (margin) are used, which are determined in the following order:    

      1) in the case when the number of values of market prices and (or) values of market profitability (margin) used for the application of these methods is equal to one value, the range is defined as equal to such a value of the market price or profitability (margin);    

      2) in the case when the number of values of market prices and (or) values of market profitability (margin) used for the application of these methods does not exceed three values, the range is defined as the range from the minimum value to the maximum value inclusive of such market prices and (or) market profitability (margin).  

      For the purposes of this subparagraph, the price range indicated in the information source as two values separated by a dash is also accepted as a range not exceeding three values.;  

     3) in the case when the number of values of market prices and (or) values of market profitability (margin) used for the application of these methods is equal to four or more values, the range is defined as the range between the twenty-fifth and seventy-fifth percentiles inclusive, calculated on the basis of the values of market prices or profitability (margin) used.

     2. To calculate the price range, market price values are used, determined in accordance with and using the same information source.

     3. To calculate the range of profitability (margin), financial data is used for three consecutive calendar years immediately preceding the calendar year in which the analyzed transaction was completed.

The Law of the Republic of Kazakhstan dated July 5, 2008 No. 67-IV.

President    

Republic of Kazakhstan     

© 2012. RSE na PHB "Institute of Legislation and Legal Information of the Republic of Kazakhstan" of the Ministry of Justice of the Republic of Kazakhstan  

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