Kazakhstan has enacted Law No. 215-VIII of 18 July 2025 "On Amendments and Additions to Certain Legislative Acts on Taxation Issues." The new rules prescribe the following amendments to the country’s transfer-pricing (TP) regime and will apply from 1 January 2026:
- Controlled transactions involving intellectual-property rights must now be analysed on the basis of the parties’ actual conduct, functions and risk profile, allowing the tax authority to re-characterise transactions that do not ref…