Article 3. Implementation of transfer pricing control Transfer Pricing Law

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1. Transfer pricing control (hereinafter referred to as control) is carried out on the following transactions:

1) international business operations.

2) committed on the territory of the Republic of Kazakhstan, directly related to international business operations:

for realizable minerals extracted by a subsurface user who is one of the parties;

one of the parties that has tax benefits;

one of the parties to which has a loss according to tax returns for the last two tax periods preceding the year of the transaction;

the parties of which have different corporate income tax rates.

2. Control is carried out by authorized bodies:

1) monitoring of transactions;

2) checks;

3) other procedures established by the laws of the Republic of Kazakhstan.

3. Excluded by the Law of the Republic of Kazakhstan dated 03/25/2024 No. 68-VIII (effective sixty calendar days after the date of its first official publication). 4. Excluded by the Law of the Republic of Kazakhstan dated 03/25/2024 No. 68-VIII (effective sixty calendar days after the date of its first official publication).

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

President

Republic of Kazakhstan

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