Monitoring international transactions in 2025: what businesses need to know
In December 2025, Kazakhstan’s approach to monitoring international transactions under transfer pricing rules entered a new phase. Regulatory changes adopted by the Ministry of Finance significantly expanded both the scope of transactions subject to monitoring and the reporting requirements for taxpayers.
On 19 December, Fortune Partners held a professional seminar dedicated to these changes, focusing on practical implications for businesses engaged in cross-border operations. The discussion made one thing clear: the new rules affect far more companies than before, and the cost of mistakes has increased.
The seminar will be of practical interest to participants in international business transactions, in particular to participants in transactions in which one party is a non-resident and the other is a resident of the Republic of Kazakhstan, as well as transactions of residents carried out outside the territory of the Republic of Kazakhstan.
Expansion of Transactions Subject to Monitoring
One of the key changes is the expanded list of controlled transactions. In addition to traditional export and import operations, monitoring now explicitly covers transactions related to:
• construction and installation works
• marketing services
• freight forwarding and logistics services
• issued and received loans
As a result, a much wider range of companies now falls within the transfer pricing monitoring framework. Businesses that previously did not consider themselves subject to these rules may now be required to submit detailed reports.
New Reporting Forms: More Detail, More Responsibility
Previously, taxpayers submitted only two monitoring forms covering export and import of goods, works, and services. The updated framework introduces separate forms depending on transaction type, including:
• export and import of crude oil and gas condensate
• export and import of goods
• income from performed works and rendered services
• issued and received loans
This change effectively elevates works and services from a secondary category to a fully regulated and independently monitored segment, requiring more precise documentation and pricing justification.
Automation and the Role of Information Sources
To standardize monitoring, several subjective indicators have been removed from reporting forms, including:
• market reputation
• qualitative product characteristics
• business strategy
• risk analysis and price forecasts
Instead, the source of pricing information has become the central element of compliance.
Under Article 18 of the Law of the Republic of Kazakhstan “On Transfer Pricing,” information sources must be applied in a strict order:
1. officially recognized sources
2. exchange quotation sources
3. data from state authorities (particularly relevant for works and services, based on NCEA codes from the Bureau of National Statistics)
4. information provided by the transaction parties
Analytical platforms such as Argus, Bloomberg, and TP Catalyst now play a decisive role. Alternative sources may be used only if pricing data is unavailable on these platforms, which significantly limits flexibility for taxpayers.
Loans and Credit Ratings: A New Key Metric
For issued and received loans, reporting forms now include a separate field for credit rating. This indicator directly affects the acceptable interest margin: the lower the borrower’s credit rating, the higher the permissible margin, and vice versa.
The purpose of the loan is also taken into account. Credit ratings must be determined using official information sources, including international analytical platforms, making documentation accuracy critical.
Electronic Invoices and Additional Tax Risks
Special attention during the seminar was given to the inclusion of electronic invoices as a separate reporting element confirming the execution of transactions.
Participants expressed concern about potential discrepancies between electronic invoices issuance dates and actual transaction dates. Such mismatches may affect monitoring outcomes and increase the risk of additional scrutiny.
Moreover, since electronic invoices are a core element of VAT administration, their use in transfer pricing monitoring may intensify desk audits and indirectly affect other tax obligations, increasing overall exposure for businesses.
Reporting Errors Are Treated as Non-Submission
In practice, completing monitoring forms has long been one of the most challenging aspects of transfer pricing compliance. Under current rules, any deviation from formal requirements may be treated as failure to submit the report.
Seminar participants highlighted a recurring issue: companies often resubmit corrected forms without understanding why the original version was rejected by the authorities. This leads to repeated errors, missed deadlines, and increased tax risks, including penalties and additional audits.
In this context, the relevance of the seminar is particularly significant, as the failure or refusal to submit transaction monitoring reports entails administrative liability in the form of fines ranging from 100 to 1,000 monthly calculation indices (MCI), depending on the category of the business entity and the number of violations committed, in accordance with Article 273 of the Code of Administrative Offenses of the Republic of Kazakhstan. Issues related to the application of preventive measures, the correct completion of reports in order to avoid their return by the authorized body, as well as compliance with the established submission deadlines, constitute practical challenges for businesses.
What This Means for Businesses
The updated monitoring rules aim to increase transparency and standardize approaches to transfer pricing control. For businesses, however, this translates into:
• broader reporting obligations
• higher technical and methodological requirements
• increased risk of penalties due to formal errors
• greater importance of internal controls and data sources
Companies engaged in international transactions must reassess their reporting processes, pricing methodologies, and documentation frameworks to remain compliant under the new rules.
Professional Support Matters
In the current regulatory environment, transfer pricing monitoring is no longer a purely technical exercise. It requires a deep understanding of legislation, pricing sources, reporting logic, and tax administration practice.
If your company needs professional support in monitoring international transactions, adapting to the 2025 rules, or reducing transfer pricing risks, Fortune Partners’ experts are ready to assist.
For consultation and cooperation: +7 707 793 12 10
