Transfer pricing issues occupies a separate niche in the tax law structure due to specifics of this area.

In this regard, control over transfer pricing is one of the main considerations of any state. It is a special type of control that differs from ordinary tax inspection and requires special approach to international business transactions.

Tax bodies exercise control on the basis of comparison between market price and the deal price and in case there is a difference, the deal price becomes a transfer price i.e. the deal price was undervalued on export or overvalued on import.

GRATA International is glad to offer the following transfer pricing services:

  • advising on application of transfer pricing law (preparation of memorandums);

  • preparation of due diligence on lawfulness of actions and decisions of the tax authorities in transfer pricing part.

Name Position Contacts
Assel Ilyasova Partner, Head of Tax Law Department Inquire
Eldar Ziatdinov Director of Tax Law Department, GRATA International (Moscow), Representative in Kazan Inquire
Nurbol Kissembayev Partner, Branch Director Inquire
Nodir Yuldashev Partner, Construction, Telecommunications, Transport, Tax and Litigation Inquire
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Kaisar Yegizbayev gave a lecture at the Caspian University

Kaisar Yegizbayev is a lawyer at the Tax law department of GRATA International. He gave a guest lecture to Caspian University students on the 'BEPS. OECD actions against aggressive tax planning'.


Clarification of the State revenue committee on deduction of losses of foreign branch of a Kazakh company

State revenue committee of the Ministry of Finance of the Republic of Kazakhstan (hereinafter – the ‘SRC’) clarified...


Corporate Tax 2016: Kazakhstan

ICLG (International Comparative Legal Guide) to: Corporate Tax 2016, 12 edition Author: Assel Ilyassova


Arctic Group International recommends GRATA

Arctic Group International LLP recommends GRATA Law firm LLP as a reliable and responsible legal advisor


JTI recommends GRATA

JTI Kazakhstan LLP recommends GRATA Law firm as a tax adviser


Representatives of grata law firm took part in the roundtable “On de-criminalization of tax violations”

The roundtable "On de-criminalization of tax violations based on the practice of the tax jurisdictions of OECD member-states" was held on June 5, 2015.


GRATA Law Firm held a workshop titled: 'Kazakhstan - Russia: legal aspects of doing business'

On 24 April 2015, in Almaty there has been a workshop titled: 'Kazakhstan - Russia: legal aspects of doing business' held by GRATA Law Firm.


GRATA Law firm is recommended as one of the leading law firms by The Legal 500 Europe, Middle East & Africa 2015

Grata Law Firm is ‘held in high regard’ by foreign clients and international law firms, and its large, full-service team.


Amendments to the tax code as effective since 1 January 2015

In 2014, 17 laws were adopted to amend the Code of Kazakhstan 'On Taxes and Other Obligatory Payments to the Budget' (Tax Code). Most of the amendments become effective from 1 January 2015. GRATA Law Firm hereby provides for the brief review of main amendments. For your convenience, amendments introduced to the Tax Code are given in a special table. We value your time and hope that the information provided will be useful for you.


Liability for tax violations under a new Code of Kazakhstan 'On Administrative Violations' and Criminal Code of Kazakhstan

A new Code of the Republic of Kazakhstan 'On Administrative Violations', dated 5 July 2014 and a new Criminal Code of the Republic of Kazakhstan, dated 3 July 2014 entered into force on 1 January 2015.


Aspects of taxation in opening business in Kazakhstan

In this article, we will review the main concepts of taxation relating to the types of legal entities in Kazakhstan.


Difficulties in Applying the Tax Legislation Provisions When Calculating a Commercial Discovery Bonus

In a society where the ownership of the subsoil belongs to the State, the latter must play at least a dual role.


Practical Recommendations for VAT Refunds

It can be said that the VAT refund procedure is complicated and time-consuming as it requires numerous documents to be confirmed and involves a tax audit of the taxpayer and its suppliers.


Tax Audits: Practical Considerations on Support and Appeals Against the Tax Audits of Subsoil Users

The performance of operations under subsoil use contracts is currently strictly supervised by the State, in particular the issues concerning the completeness and timeliness of the performance by mining companies of their tax obligations.


The EPT Calculation Problems

One of the brightest examples of tax policy changes relating to Kazakhstan subsoil users is a situation with the excess profit tax (EPT) calculation.


Regulatory Legal Acts Developed in Performance of the New Law of the RK on Transfer Pricing

The Law of the Republic of Kazakhstan ‘On Transfer Pricing’ (hereinafter – the ‘Law’) contains references to the regulatory legal acts


Comments on the Amendments to the Law of the Republic of Kazakhstan “On Transfer Pricing”

Hereby we would like to provide brief comments to amendments to the Law ‘On Transfer Pricing’, as well as the description of difficulties that may be faced in the course of applying the amendments.


Calculation Method for Transfer Pricing in Kazakhstan

This method has been based on available methodological base for the control of transfer pricing and is designed to calculate and minimise the risks associated with transfer pricing.


Relevance of the Tax Inspections on Transfer Pricing

The Kazakhstan Tax authorities inspect the matters of transfer pricing.


Problems with Obtaining Refunds from the Budget of Excess VAT Accumulated During Mineral Exploration

Lately, obtaining a refund of value added tax (VAT) incurred in connection with the export of goods[1] has been a pressing issue.


Review of the Amendments made to the Tax Code and Administrative Code in 2013

On 26 December 2012 the President of the Republic of Kazakhstan signed the Law On Amendments to Some Legislative Acts of the Republic of Kazakhstan on Taxation.


Review of the Regulatory Resolution of the Supreme Court of the Republic of Kazakhstan 'On the Judicial Practice of Application of the Tax Law'

On 27 February 2013 the Supreme Court introduced the Regulatory Resolution 'On the Judicial Practice of Application of the Tax Law' (hereinafter - the 'Resolution').


Kazakhstan: New Investment Climate

During the 27th session of the Foreign Investors’ Council held on 12 June 2014, the President of Kazakhstan Mr. Nursultan Nazarbayev announced the establishment of a unilateral visa-free regime for citizens of 10 countries.


Some Taxation Issues in the Oil and Gas Industry

The Republic of Kazakhstan possesses significant reserves of oil and gas, which means the oil and gas industry holds the leading position in the structure of the national economy. Therefore the tax system in this sector needs to provide stability, transparency and progressivity,, take into account the general global situation and encourage investment.


Review of the Developments in the Tax Law of the Republic of Kazakhstan: International Taxation

Kazakhstan ratified the Double Taxation Treaties signed with the United Arab Emirates and the Grand Duchy of Luxembourg


Astana , March 31, the first meeting of the ANK Working Group on the improvement of subsoil user taxation.

On March 31 the first meeting of the Working Group on the Improvement of Subsoil-User Taxation was held at the House of Ministries in Astana. The meeting was organized by the Taxpayers Association of Kazakhstan (APK ).


On April 4th, 2014 in Pavlodar the seminar on "Legal Aspects of Tax Audits and Appealing against Results. International Taxation" tookplace.

The seminar explored the various issues in depth and focused on problems that customers often encounter in practice.


Luiza Dyussengaliyeva participated in the AmCham Astana Tax Working Group Meeting

Astana Tax Working Group of the American Chamber of Commerce in Kazakhstan (AmCham) held its meeting on February 17, 2014.


On 18 March, ITIC convened a meeting of the Caspian Minerals Tax Committee (CMTC) in Astana, organized jointly with Ernst & Young KZ.

The event was attended by officials from the Tax Committee of the Ministry of Finance of the Republic of Kazakhstan, including Deputy Chairman Argyn Kipchakov, Head of Large Taxpayers Department Daniyar Zhanalinov and Head of VAT Administration Department Nurlan Rakhimgaliev, as well as senior experts of several TC departments.


Corporate Lawyers Forum was Held in Almaty with Participation of GRATA Representatives

On 6-7 November 2014 the IX Kazakh Forum of Corporate Lawyers was held in Almaty.

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Assel Ilyasova

Partner, Head of Tax Law Department


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