Effective: May 2027
Kazakhstan's authorities have introduced material changes to the transfer pricing framework applicable to participants in the Astana International Financial Centre (AIFC), affecting how intra-group transactions between AIFC-registered entities and related parties — including non-resident parents and subsidiaries — must be documented and priced.
Foreign investors and multinational groups that hold Kazakhstani assets, operate through AIFC-registered vehicles, or conduct cross-border transactions between Kazakhstan and other jurisdictions — including Russia and other EAEU member states — are directly affected. Under the revised framework, the documentation requirements for controlled transactions have been strengthened: groups meeting the applicable revenue threshold are now expected to maintain a local file aligned with OECD-standard content requirements, even where the AIFC's preferential tax treatment would otherwise apply. The practical consequence is that the compliance burden for intra-group service fees, royalties, and financing arrangements has increased — and the window for retrospective adjustment is limited.
Recommended action:
- Identify all controlled transactions involving your AIFC-registered entity — including management fees, intercompany loans, and intellectual property licences — and assess whether existing documentation meets the updated standard.
- Review whether the revenue threshold for mandatory local-file preparation applies to your group's Kazakhstan operations for the current reporting period.
- Seek local Kazakhstan counsel to confirm whether any transitional filing deadlines apply and whether voluntary disclosure of prior-period pricing positions is advisable before the competent authority begins its review cycle.
[CTA: To discuss how these changes affect your Kazakhstan operations — make an enquiry: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76]
For further context on the Kazakhstani tax and regulatory framework for foreign investors, see our Kazakhstan jurisdiction page (/jurisdictions/kazakhstan/) and the Tax practice overview (/jurisdictions/kazakhstan/tax/). Foreign investors active across the region may also wish to review parallel developments in Uzbekistan (/jurisdictions/uzbekistan/tax/) and Armenia (/jurisdictions/armenia/tax/).
H2: About Vetrov & Partners
Vetrov & Partners is a boutique law firm established in 2009, recognised by Pravo-300 for eight consecutive years. The firm advises foreign investors on cross-border matters across Russia and the broader CIS and EAEU region, including Kazakhstan. Enquiries: info@vetrovpartners.com | WhatsApp / Telegram: +7 (983) 510-38-76 | t.me/vitvetcom
We are a Russian-qualified law firm. For matters governed by Kazakhstani law or requiring local admission, we collaborate with trusted counsel in Kazakhstan.
This alert is for informational purposes only and does not constitute legal advice. Vetrov & Partners is a Russian-qualified law firm. Contact info@vetrovpartners.com for advice on your specific situation.
— Aigerim Serikbayeva Contributing Regional Analyst — Kazakhstan, Vetrov & Partners vetrovpartners.com/contributions/