1) TP seminar is scheduled for April 24-25, 2025, with a fee of 448,000 KZT or 903 USD per participant.
Almaty
Please be aware that all registered participants must first undergo our internal risk management procedures. This process may take some time, and participation cannot be guaranteed until these procedures are approved.
Day 1 – April 24, 2025, 14.00 - 17.00:
Fundamentals and principles of transfer pricing (“TP”)
- types of control;
- selection and application of TP methods;
- sources of information;
- the latest developments in the field of TP.
Overview of pre-trial and complex practices (examples of current court cases and discussions of controversial issues)
- application of spread on oil supplies;
- application of KEBCO quotations;
- financial transactions.
Adopted and planned amendments to the TP legislation
- broadened scope of taxpayers required to submit monitoring reports;
- potentially new categories of transactions falling under the definition of "international business transactions";
- new categories of individuals under the definition of "interrelatedness of the parties";
- impact of TP Law amendments on taxpayer profitability (margins);
- limitation of the market range and application of median value in adjustments;
- emphasis on substance over form;
- reduced timeframe for providing information and documents confirming the validity of the transaction price upon request by authorities.
Day 2 – April 25, 2025, 14.00 - 17.00:
Analysis of nuances and common mistakes in preparing transfer pricing documentation, as well as our recommendations for completing the form:
- local documentation;
- statement of participation in an international group;
- transaction monitoring reporting.
Conducting market data research (algorithms for searching comparable companies/data, determining the market range, profitability calculation) for the following transactions:
- distribution;
- financial transactions;
- intra-group services;
- intra-group services;
- licensing of intangible assets.
Practical application of transfer pricing:
- conducting transfer pricing adjustments in practice.
Registration link: https://forms.office.com/r/iuLtiYT9iS
More details at: https://www.pwc.com/kz/en/transfer-pricing-24-25-april-2025.pdf
2) ITS seminar is scheduled for May 14-15, 2025, with a fee of 380,000 KZT or 778 USD per participant.
Aktau
Please be aware that all registered participants must first undergo our internal risk management procedures. This process may take some time, and participation cannot be guaranteed until these procedures are approved.
1. Conceptual Foundations of International Taxation and Their Application by Kazakhstan's Tax Authorities:
- Residency and Source of Income;
- Permanent Establishment and Its Income;
- Ultimate Beneficiary of Income and How to Determine It;
- Tax Conventions and Procedures for Their Application.
2. Measures to Combat Tax Evasion (BEPS):
- Basics of the Multilateral Convention MLI, Minimum Standard, and Optional Provisions;
- Principal Purpose Test (PPT) and Simplified Limitation on Benefits (SLoB);
- Kazakhstan's Position on MLI;
- Preparation of "Defense Files" in Practice;
- Pillar 2: Goals and Key Rules.
3. Issues in Preparing Tax Reporting Form 101.04:
- Retrospective Changes in the Tax Reporting Form;
- Inquiries and Desk Audits by Tax Authorities on the Data in Submitted Declarations.
4. Practice of International Taxation: Cases, Trends, and Recommendations.
5. Q&A Session.
Registration link: PwC семинар, 14-15 мая 2025 г.
More detail at: 14-15-may-2025.pdf