OECD still waiting for Kazakhstan’s tax report exchange procedures

Château de la Muette in Paris, OECD headquarters, 2019
Archive photo. Source: MySociety / Wikimedia Commons, CC BY 2.0

Astana, 30 October. The Organisation for Economic Co-operation and Development (OECD), in its annual report on country-by-country reporting by multinational groups, has again recommended that Kazakhstan put in place processes or written procedures for exchanging such reports with other countries — ahead of its first exchanges; the recommendation has stood since the 2018/2019 review.

The report, Country-by-Country Reporting — Compilation of 2026 Peer Review Reports, came out on 19 October. It is the ninth annual review of how countries implement the minimum standard of Action 13 of BEPS — the OECD/G20 programme against base erosion and profit shifting to low-tax jurisdictions; 142 jurisdictions were assessed. The review covers three areas: domestic legislation, the exchange of information framework and the appropriate use of the reports received. Country sections reflect the position as of 31 March 2026, and exchange data as of 31 December 2025.

In two of the three areas Kazakhstan has no recommendations: the country confirmed that its rules have not changed and are applied, and in the OECD’s assessment it continues to meet all requirements on legislation and on the use of reports. The only recommendation concerns exchange. The wording “ahead of its first exchanges of information” means that, in the OECD’s assessment, Kazakhstan has not yet exchanged such reports with other jurisdictions.

In the Kazakhstan section of the report this recommendation carries a short note: it has remained in place since the 2018/2019 peer review. Since then the OECD has also been monitoring two more points: what Kazakhstan will do if another country’s tax authority reports an error or incomplete information in a group’s report, and whether local filing is switched off when a group has filed through another company — a so-called surrogate parent. Kazakhstan says it is; the monitoring point remains.

What it means: The requirements for large multinational groups in Kazakhstan are in place and working, but the very exchange of their reports with other countries’ tax authorities — the purpose of the system — has not been set up in eight years.

Who benefits: Multinational groups — as long as Kazakhstan does not exchange reports, their tax picture in the country is less visible to foreign tax authorities. A working exchange would give Kazakhstan’s tax authorities information on where groups operating in the country book their profits; the sources do not say when Kazakhstan intends to start.

Background: A country-by-country report is filed by multinational groups with consolidated annual revenue of 750 million euros or more: for each country it shows revenue, profit, taxes paid and number of employees. In Kazakhstan the requirement applies to fiscal years starting on or after 1 January 2016, and the report is due within 12 months of the year’s end. According to the report’s findings, 110 of the 142 jurisdictions have competent authority agreements for exchanging such reports; 19 jurisdictions received a general recommendation to put in place or finalise their legal framework.

We have also reported that ministries were given a month to study world experience of a wealth tax.

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