LawIn force
Transfer Pricing Law
Law of the Republic of Kazakhstan “On Transfer Pricing”
Governs state control of prices in cross-border transactions and related domestic deals to ensure they follow the arm's length principle. It is especially relevant for exports of crude oil, gas and other commodities and for intra-group deals.
What matters for an oil & gas company
- Control covers international business transactions and domestic deals directly linked to them: sales of minerals extracted by a subsoil user party, deals with a party that has tax incentives or tax losses in the last two years, or between parties with different CIT rates.
- The market price is set by the comparable uncontrolled price, cost plus, resale price, profit split or net profit methods; exchange quotations are used for traded commodities.
- Members of international groups file local, master and country-by-country reports; transactions on an approved list are monitored.
- If the price deviates from the market price, the tax authority audits the deal and may adjust taxable items.
The summaries are for orientation and are not legal advice. Only the official text is legally binding. Checked in September 2026.