Country-by‑Country Reporting – Compilation of 2025 Peer Review Reports

Kazakhstan

Overview of CbC reporting requirements

First reporting fiscal year: Commencing on or after 1 January 2016

Consolidated group revenue threshold: EUR 750 million

Filing deadline: 12 months following the end of the reporting fiscal year

Local filing required: Yes

Surrogate parent entity filing permitted: Yes

First review of the domestic legal framework: 2018-2019

Summary of recommendations

Area of implementation	Recommendations for improvement
Domestic legal and administrative framework	None.
Exchange of information framework	It is recommended that Kazakhstan take steps to implement processes or written procedures to ensure that the exchange of information is conducted in a manner consistent with the terms of reference relating to the exchange of information framework ahead of its first exchanges of information.
Appropriate use	None.

The domestic legal and administrative framework

Kazakhstan’s 2018-2019 peer review recommended that Kazakhstan takes steps to clarify the exact scope, conditions, and legal basis under the minimum standard and/ or the exchange of information framework for the exemption in case of state secrets. Kazakhstan amended it legislation to remove the reference to state secrets and this recommendation is removed.1

Kazakhstan’s 2018-2019 peer review recommended that Kazakhstan implement a provision or otherwise clarify that a single Constituent Entity of the same MNE Group may be designated to file the CbC report which would satisfy the local filing requirement of all the Constituent Entities in Kazakhstan. Kazakhstan clarified that its legislation allows for a single Constituent Entity to satisfy the local filing requirement of all the Constituent Entities in Kazakhstan and this recommendation is removed. 2 3

Kazakhstan’s 2022-2023 peer review recommended that Kazakhstan clarify that the annual consolidated group revenue threshold calculation rule applies in line with the OECD guidance on currency fluctuations in respect of an MNE Group whose Ultimate Parent Entity is located in a jurisdiction other than Kazakhstan. Kazakhstan has clarified that under its legislation local filing requirements cannot be applied in respect of a Constituent Entity (which is a Kazakhstan tax resident) of an MNE Group which does not reach the threshold as determined in the jurisdiction of the Ultimate Parent Entity of such a Group, and the recommendation is removed.

The exchange of information framework

It is recommended that Kazakhstan take steps to implement processes or written procedures to ensure that the exchange of information is conducted in a manner consistent with the terms of reference relating to the exchange of information framework ahead of its first exchanges of information. This recommendation remains in place since the 2018-2019 peer review.

Kazakhstan’s 2023-2024 peer review recommended that Kazakhstan take steps to ensure that the number of reports received and exchanged are monitored. Kazakhstan has supplied information on the reports it has received from MNE Groups and which it has exchanged and the recommendation is removed.

Appropriate use of CbC reports

Kazakhstan confirms that its rules have not changed and continue to be applied effectively. Kazakhstan continues to meet all terms of reference.

Notes

← 1.  https://adilet.zan.kz/rus/docs/Z080000067_#z314

← 2.  Kazakhstan’s 2018/19 peer review included a general monitoring point relating to the processes that would allow Kazakhstan to take appropriate measures in case Kazakhstan is notified by another jurisdiction that it has reason to believe with respect to a Reporting Entity that an error may have led to incorrect or incomplete information reporting or that there is non-compliance of a Reporting Entity with respect to its obligation to file a CbC report. This monitoring point remains in place.

← 3.  Kazakhstan’s 2018/19 peer review included a monitoring point as it is unclear whether Kazakhstan’s legislation provides for the deactivation of local filing in case of surrogate filing. Kazakhstan state that this is the case. This monitoring point remains in place.