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On 8 February 2022, a draft of the Order of the Minister of Finance of Kazakhstan “On Approval of the Rules for concluding an advance pricing agreement” (hereinafter - "APA") was published for discussion on Kazakhstan’s e-government website.
This draft Order defines an APA as a written agreement between the State Revenue Committee of the Ministry of Finance of Kazakhstan (hereinafter - the "SRC") and a taxpayer establishing a method and a source of information for determining market prices for a certain period.
We would like to highlight the following key changes in the draft APA rules as compared to the current Government Decree №1197 dated 24 October 2011 “On approval of the Rules for concluding an advance pricing agreement”:
- The APA structure has been extended.
- The list of documents that should be attached to an APA application has been changed.
- The procedure for a taxpayer’s hearings at the SRC has been introduced based on the results of which a decision should be made whether to conclude an APA or not.
- A unilateral termination an APA at SRC’s discretion in case of a violation of the APA resulting in a loss of state revenue has been introduced.
Authors:
- Anuar Mukanov
- Yuliya Barsukova