KAZAKHSTAN Law and Practice Contributed by: Assel Ilyassova, Lyazzat Zhilkibagarova and Makhabbat Mukhidinkyzy, GRATA International
9. Dispute Prevention 9.1 Advance Pricing Agreements
Kazakhstan has an advance pricing agreement pro - gramme. The legal basis for the programme is the Kazakh Law on Transfer Pricing. 9.2 Other Mechanisms Kazakhstan does not have a broad binding ruling or co-operative compliance system for international tax matters comparable to those available in some OECD jurisdictions. Tax certainty in treaty matters is available primarily through the MAP under the applicable dou - ble tax treaties. In addition, taxpayers participating in the horizontal monitoring regime may obtain pre - liminary explanations from the tax authorities on the application of tax legislation, including tax treaties. More generally, the tax authorities may issue individual written explanations; however, these are advisory only and are not legally binding.
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