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Country-by-Country Reporting – Compilation of Peer Review Reports (Phase 1)

Inclusive Framework on BEPS: Action 13

image of Country-by-Country Reporting – Compilation of Peer Review Reports (Phase 1)

Under the Action 13 Minimum Standard, jurisdictions have committed to foster tax transparency by requesting the largest multinational enterprise groups (MNE Groups) to provide the global allocation of their income, taxes and other indicators of the location of economic activity. This unprecedented information on MNE Groups’ operations across the world will boost tax authorities’ risk-assessment capabilities. The Action 13 Minimum Standard has been translated into specific terms of reference and a methodology for the peer review process. The peer review of the Action 13 Minimum Standard is proceeding in stages with three annual reviews in 2017, 2018 and 2019. The phased review process follows the phased implementation of Country-by-Country (CbC) Reporting. Each annual peer review process will therefore focus on different aspects of the three key areas under review: the domestic legal and administrative framework, the exchange of information framework, and the confidentiality and appropriate use of CbC reports. This first annual peer review report reflects the outcome of the first review which focused on the domestic legal and administrative framework. It contains the review of 95 jurisdictions which provided legislation or information pertaining to the implementation of CbC Reporting.

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Kazakhstan

1. Consistent with the agreed methodology this first annual peer review covers: (i) the domestic legal and administrative framework, (ii) certain aspects of the exchange of information framework as well as (iii) certain aspects of the confidentiality and appropriate use of CbC reports. Kazakhstan indicates that it has legislation in place to implement the BEPS Action 13 minimum standard. However, because the law was enacted on 25 December 2017, Kazakhstan was unable to provide a translation of the legislation in due course. Therefore, it was only possible to carry out a very preliminary review for this first annual peer review process based on some initial information. Based on this initial information, Kazakhstan’s domestic and legal administrative framework may potentially raise one substantive issue. The domestic legal and administrative framework will however be assessed in the next annual peer review process (and the preliminary recommendation contained in this report may therefore be later amended based on further information). In addition, it is recommended that Kazakhstan put in place an exchange of information framework as well as measures to ensure appropriate use.

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