Transfer Pricing: Defending Your Transaction Prices Before the Tax Authorities

We support companies on all transfer pricing matters: transaction analysis and documentation, justification of prices applied, reporting, support during transfer pricing audits, and disputes with tax authorities. We have advised on transactions totalling $200 million.

Kazakhstan's transfer pricing regulation is among the most stringent: controlled transactions include not only intra-group dealings but also international business operations with independent parties. For commodity exporters and companies with cross-border transactions, the question is not whether your prices will be reviewed — but whether your justification will hold up when they are.

Situations Where We Step In:

The company exports commodities — transactions automatically fall under transfer pricing control
The group conducts cross-border operations: loans, services, royalties, supplies between related parties
A transfer pricing audit has started or is expected
The tax authority has requested price justification or assessed additional tax with a transaction price adjustment
A major deal is planned — the price needs to be justified before signing, not after a request
The company is unsure whether transfer pricing control applies to its operations and what reporting is mandatory

Our Approach:

We define the control perimeter: which of your transactions fall under transfer pricing regulation and what obligations follow — many companies already err at this step;
We justify prices methodologically: information sources, applicable methods, ranges, differentials — so that the justification withstands an audit, not merely exists;
We prepare transfer pricing documentation and reporting in full compliance with legal requirements;
We support audits and disputes: from responses to requests through to appealing additional assessments at every level;
We track trends and regulatory changes — and tell clients in advance what to change in their approaches before it becomes a claim.

Why Us

Experience from Three Sides: Consultant, Tax Authority, Taxpayer

Transfer pricing is a field where knowing the law is not enough: you need to understand methodology, the inspectors logic, and business reality at once. Our transfer pricing specialists gained that experience first-hand — working as Big Four consultants, in the tax authority, and on the side of a major taxpayer.

We know how a transfer pricing audit is built from the inside: which information sources the authority uses, how adjustments are formed, and which arguments are accepted. Among our results is transfer pricing advice on transactions totaling $200 million.

We give practical recommendations, not theoretical memoranda: for every issue you get a position that can be applied and defended.

Our Cases.
How we helped our clients

When court decisions to invalidate transactions do not result in additional assessments

Brief description of the case:

When a desk audit notification arrives referencing already-issued civil court decisions

Experience from Three Sides: Consultant, Tax Authority, Taxpayer

When It Is Important to Reach Out

Get an Initial Analysis of Your Situation

The Key to Success