Strengthening the capacity to tackle tax avoidance in Kazakhstan
Context
Kazakhstan is the world’s largest landlocked country, bridging Central Asia and Eastern Europe. Following its independence from the Soviet Union in 1991, Kazakhstan’s expanding market-based economy and its large quantity of natural resources – which include deposits of gold, hydrocarbons, and uranium, amongst many others – have enabled the country to emerge as the largest economy in Central Asia and a key hub for regional logistics, trade and investment.1 Kazakhstan’s abundance of natural resources has fuelled national and foreign investment in the oil, metal and mining sectors.2 The economic expansion of these sectors has encouraged an ever-growing presence of multinational enterprises (MNEs), which has bolstered Kazakh economic prosperity through investment, technology and skills. Over the past 10 years, however, Kazakhstan’s growth has slowed from 10% (over 2000-2007) to below 4%, highlighting the vulnerabilities of an economy still dependent on hydrocarbons and with stagnant productivity growth.3
This case study illustrates how Kazakhstan has benefitted from support in international tax capacitybuilding. After working with the OECD for over a decade, the country has been able to strengthen its capacity and identify key issues, which include tax avoidance in the mining sector, as well as areas for improvement in the legal transfer pricing framework. Kazakhstan has also enhanced its access to tools for exchange of information and has strengthened its tax-treaty network. It has achieved an increase in tax revenues through improved tax audit capacity, emerging as a leader in the region.
The OECD conducted a Tax Policy Review of Kazakhstan in 20204, which found that higher tax revenues were needed to meet the country’s expenditure goals and to reduce the non-oil deficit.5 The tax-to-GDP ratio in Kazakhstan has characteristically been low, volatile and very sensitive to economic cycles.6 Important sources of tax
revenue, such as corporate income tax (CIT), rely on the extractive sectors, including mining and fossil fuels, and depend on international oil prices. Recently, the tax-toGDP ratio in Kazakhstan increased by 4.2 percentage points, from 15.6% in 2021 to 19.8% in 2022.7
The State Revenue Committee8 has encountered a multitude of tax challenges related to the CIT of MNEs. Base erosion and profit shifting (BEPS) practices have directly impacted Kazakhstan’s capacity to protect its tax base and enhance domestic resource mobilisation (DRM). The tax administration has found it difficult to address the complex operations and business models of the MNEs, which is compounded by limited access to information regarding transactions involving multiple jurisdictions. For example, to increase CIT deductions in Kazakhstan and shift profits to related companies located in no- or low-tax jurisdictions, MNEs operating in the mining sector undervalued exported minerals and engaged in complex financial transactions.
Kazakhstan’s engagement on international tax issues
As part of a global effort to fight bank secrecy and promote tax co-operation, in 2012 Kazakhstan joined the Global Forum on Transparency and Exchange of Information for Tax Purposes,9 subsequently undergoing the related peer review processes.10 In 2013, Kazakhstan was welcomed as an Invitee to the OECD’s Committee on Fiscal Affairs (CFA),11 the committee responsible for the OECD’s work on tax matters. In 2016, the country joined the OECD/G20 Inclusive Framework on BEPS (the Inclusive Framework),12 an international collaboration of 147 countries and jurisdictions working together to end tax avoidance by MNEs. As an Inclusive Framework member, Kazakhstan contributes to developing new international tax standards on BEPS. In October 2021, Kazakhstan joined the Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalisation of the Economy (the Two-Pillar Solution).13 On 11 July 2023, Kazakhstan joined the 138 members of the Inclusive Framework that agreed an Outcome Statement14 identifying the progress made on the Two-Pillar Solution, as well as the next steps; this Statement has subsequently been joined by all new members of the Inclusive Framework. Kazakhstan has also benefitted from the induction programme for new Inclusive Framework members, a capacity-building programme on transfer pricing, and a Tax Inspectors Without Borders (TIWB)15 programme. A joint initiative of the United Nations Development Programme (UNDP) and the OECD, TIWB deploys tax experts around the world to help developing countries build international tax audit and investigation capacity through a practical hands-on approach, working on real cases.
Since 2019, Kazakhstan is a Participant16 in the Joint Meeting of Tax and Environment Experts, which brings together officials from the tax and environment ministries of OECD and partner countries to exchange information
on and experience in the use of environmentally related taxation. Most recently, in 2023, Kazakhstan joined the Inclusive Forum on Carbon Mitigation Approaches (IFCMA)17. Launched in February 2023, the IFCMA seeks to strengthen global climate mitigation action through support to multilateral dialogue for improved data and information sharing, as well as evidence-based mutual learning. Kazakhstan also participates in the OECD’s Revenue Statistics in Asia and the Pacific, 18 a publication that has encouraged additional analytical efforts to implement strategic tax policy recommendations, as reflected in the OECD’s Tax Policy Review of Kazakhstan.
From left to right:
Nauryzbek Abduokhapov – Senior Expert of the Transfer Pricing Division
Nicholas Dluzniak – TIWB Expert
Kanat Dospanov – Head of the Transfer Pricing Division
Tomas Balco – Senior Tax Adviser, OECD
Alibek Ibrayim – Director
Sanzhar-Ali Sabyrkhanov – Expert of the Transfer Pricing Division
Senior officials from the State Revenue Committee, Specialised Department, Kazakhstan gathering with OECD and TIWB experts during a capacity-building mission focused on the mining sector, Astana, 2024.
Kazakhstan’s key achievements
Kazakhstan has:
l signed and ratified the Convention on Mutual Administrative Assistance in Tax Mattersa (MAAC).
l signed and ratified the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPSb (known as BEPS Multilateral Instrument or BEPS MLI).
l achieved significant results in transfer pricing audits, including in the period 2021-23:
– USD 211 million in additional assed tax, to which tax base adjustments of USD 264 million in four audit cases conducted under the TIWB programme contributed.
– USD 174 million in additional collected tax.c
l implemented the full transfer pricing documentation package, as recommended by BEPS Action 13, including Country-by-Country Reporting.
l promoted regional tax co-operation, hosting (between 2019 and 2024) 35 regional events and trainings on BEPS and transfer pricing – including targeted sessions on financial transactions –involving nine countries with an average of 32 participants per event.
Source: OECD
a. https://www.oecd.org/en/topics/convention-on-mutual-administrative-assistance-in-tax-matters.html
b. https://www.oecd.org/en/topics/beps-multilateral-instrument.html
c. The difference in assessed and collected tax is due to a lag between the time additional tax is assessed and when the tax due on those assessments is collected from taxpayers.
Discussion of lessons from the capacity-building programmes and follow-up actions, led by the Vice Minister of Finance, Mr Birzhanov Yerzhan Yerikuly, Kazakstan, with his senior officials and the OECD and TIWB experts, Astana, 2024.
Building of the State Revenue Committee of Kazakhstan, Astana.
A leader in Central Asia
Kazakhstan and the other Inclusive Framework members are committed to the consistent implementation of the BEPS Package of measures to address CIT avoidance, which comprises 15 actions to improve the substance, coherence and transparency of the international tax system. Among the 15 actions, four are minimum standards that all members of the Inclusive Framework are committed to implementing. Induction programmes are available to assist new members in implementing the BEPS Package.
In November 2017, following Kazakhstan’s joining the Inclusive Framework, OECD officials made a highlevel induction visit to Astana to launch the BEPS induction programme. They met with the then Minister of Finance; in a technical session with tax officials, a roadmap for the implementation of the BEPS minimum standards was discussed. The induction programme helped Kazakhstan to implement the following BEPS minimum standards:
BEPS Action 5 – Harmful Tax Practices – addresses the risks of preferential tax regimes and provides for the exchange of information on tax rulings. Kazakhstan’s tax laws were reviewed to determine whether they included preferential regimes and whether they were harmful or potentially harmful to other countries. Recommendations were made regarding two regimes: the Astana International Financial Centre regime and the Special Economic Zones regime. In 2022, Kazakhstan made changes to both regimes and these are now considered “not harmful (amended)”.19 The regimes are subject to annual monitoring by the Forum on Harmful Tax Practices, the CFA’s subsidiary body, created in 1998 and charged with conducting reviews of preferential regimes.
Kazakhstan’s proactive approach has allowed other countries in the region to benefit from the capacitybuilding activities that the OECD and other partners have provided.
Kazakhstan has also participated in the peer review on the exchange of information on tax rulings; the country received recommendations for improving the information gathering process and the domestic legal framework, as well as for completing and exchanging templates with other countries on relevant rulings.20
BEPS Action 6 – Tax Treaty Abuse – addresses risks of a country’s tax treaties being used in inappropriate ways, namely through treaty shopping. The Action 6 minimum standard requires that Inclusive Framework members’ tax treaties contain: an express statement, generally in the preamble, stating that the common intention of the parties is to eliminate double taxation without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance, including through treaty shopping arrangements; a treaty provision for implementing that common intention, which can take one of several forms. The BEPS MLI was developed to allow countries to efficiently implement the Action 6 minimum standard and other treaty-related measures of the BEPS Package across their treaty networks without having to renegotiate treaties on a bilateral basis. Kazakhstan signed the BEPS MLI in June 2018 and deposited its instrument of ratification, listing all its non-compliant agreements, in June 2020. The BEPS MLI entered into force for Kazakhstan on 1 October 2020; its provisions have already started to take effect in more than 60% of Kazakhstan’s treaty network (34 out of 55 treaties), as evidenced by the Sixth Peer Review Report on Treaty Shopping.21 The coverage will increase as Kazakhstan’s treaty partners continue to ratify the BEPS MLI.
BEPS Action 13 – Transfer Pricing Documentation –requires Inclusive Framework members to put in place
obligations for MNEs to provide details of their global allocation of income, profits, taxes paid and economic activity in the tax jurisdictions in which they operate (country-by-country reports). Tax administrations can use the country-by-country reports as high-level risk assessment tools to identify transfer pricing and other potential BEPS risks.
In 2023, Kazakhstan completed the requirements for sending and receiving country-by-country reports. This included putting in place a domestic filing obligation and Qualifying Competent Authority Agreements, as well as meeting the confidentiality and appropriate use requirements. Although the Peer Review Report22 has identified a few remaining areas for improvement, Kazakhstan is now able to receive country-by-country reports through automatic exchange of information. Consequently, country-by-country reports were sent by other countries to Kazakhstan in 2024. Kazakhstan thus became the first country in Central Asia to implement all the elements of the BEPS minimum standard on country-by-country reporting.
In addition, Kazakhstan has introduced the two other elements of the three-tiered approach to transfer pricing documentation, as recommended by BEPS Action 13. These comprise providing the State Revenue Committee with detailed information on MNEs’ operations (through a master file), as well as transactional data and qualitative information on how MNEs structure and price their related-party transactions (through a local file). Access to this information enables Kazakhstan to identify transfer pricing and other BEPS risks more precisely, thereby improving the efficiency of fact and data collection, as well as analytical efforts during tax audits.
Kazakhstan joined the BEPS project at the end of 2016 and since then we have been working on the implementation of these standards. Through this project, Kazakhstan has implemented a multilateral convention that amended our bilateral tax treaties. We also introduced a three-tier transfer pricing documentation. These measures resulted in improved tax policy and tax administration.
Mr Duysembiev Zhandos Zhumabayevich, Chairman of the State Revenue Committee, Kazakhstan
BEPS Action 14 – Mutual Agreement Procedure (MAP) –requires that Inclusive Framework members have in place the rules and procedures required to ensure timely resolution of cross-border tax disputes arising from the application of their tax treaties. The peer reviews of most developing countries were deferred until the end of 2022 due to the low number of MAP cases. Because of its important tax treaty network, Kazakhstan is one of few developing countries to participate in the full peer review process under Action 14; this was done in two stages, between 201923 and 2022.24 Although Kazakhstan has faced resource constraints and policy level obstacles, the peer review process has helped the country to understand the requirements under the BEPS Action 14 minimum standard and to establish a roadmap on actions needed to bolster its tax certainty programme. Kazakhstan is scheduled to be peer-reviewed again in April 2026 to assess the efforts made to improve its MAP policies and practices.
Strengthening transfer pricing skills in Kazakhstan and the region
While assistance on BEPS implementation was ongoing throughout the induction programme, the State Revenue Committee requested additional capacity-building support on transfer pricing; this support began in 2019. Kazakhstan hosted a regional roundtable on transfer pricing in November 2019, attended by 25 participants from nine countries. Given the success of this regional event, Kazakhstan and the OECD agreed to extend invitations to participate in a series of workshops and trainings for tax auditors to other countries in the region. The initial capacity-building activities were carried out in person, but the Covid-19 pandemic made it necessary to transform these into a virtual format. Four virtual events on transfer pricing took place from 2020 to 2022, each involving an average of 50 participants from the region.
The State Revenue Committee subsequently asked for assistance to be provided through a TIWB programme. From April 2020 to April 2024, two TIWB experts supported Kazakhstan’s transfer pricing audits in the extractive industry, involving both pricing of exported commodities and financial transactions.
The TIWB programme revealed a need for in-depth training to enable tax officials to analyse complex financial transactions and apply the guidance on financial transactions developed through the BEPS Project and incorporated in Chapter X of the OECD Transfer Pricing Guidelines. Between 2022 and 2024, TIWB and OECD experts delivered a total of 30 virtual, tailor-made workshops on BEPS and financial transactions. Kazakhstan invited tax officials of Azerbaijan, Georgia, Mongolia and Ukraine to join in the workshops, each of which was attended by an average of 30 tax officials. The events dealt with conceptual issues involving complex financial transactions being exploited
Vice Minister of Finance, Mr Birzhanov Yerzhan Yerikuly, Kazakhstan offering recognition awards to the OECD official (above) and the TIWB expert (below), Astana, 2024.
for BEPS purposes, including cases presented by Kazakh tax officials and their colleagues from the region.
Since the first regional roundtable in November 2019, Kazakhstan hosted in total 35 regional events and trainings on BEPS and transfer pricing at the time of this writing involving nine countries with an average of 32 participants per event.
Thanks to the careful co-ordination of the technical assistance programmes, Kazakhstan was able to benefit from the required training and capacity-building on transfer pricing while also receiving the guidance of foreign TIWB experts on complex tax audits related to transfer pricing.
The joint work on tax audits revealed that some tax avoidance practices in Kazakhstan resulted from gaps in the existing transfer pricing law as well as discrepancies when compared to the OECD Transfer Pricing Guidelines.
Significant additional tax revenues in Kazakhstan thanks to the TIWB programme
The audits conducted in Kazakhstan under the TIWB programme led to additional tax base adjustments of USD 264 million in four audit cases between 2021 and 2023. This, in turn, resulted in the assessment of additional tax of USD 94 million, of which USD 70 million had been collected at the time of this writing.a
Source: TIWB
a. The difference in assessed and collected tax is due to a lag between the time additional tax is assessed and when the tax due on those assessments is collected from taxpayers.
The joint OECD and UNDP programme Tax Inspectors Without Borders helped to improve our transfer pricing administration. Participation in this programme has enhanced the ability of our tax auditors to assess cross-border transactions, resulting in new approaches to transfer pricing control and better countering capital flight.
Mr Duysembiev Zhandos Zhumabayevich, Chairman of the State Revenue Committee, Kazakhstan
With support from the OECD, Kazakhstan has developed amendments to its transfer pricing law, bringing elements of the legal framework closer to the international standard. These amendments were approved by Parliament and signed by the President of Kazakhstan on 25 March 2024, entering into force on 27 May 2024.
Kazakhstan has faced the challenge of developing strategies and policies to ensure staff retention among talented transfer pricing experts. The departures of skilled tax officials has harmed the country’s ability to effectively apply and administer tax rules, and to fully benefit from the implementation of the BEPS measures. During a mission to Kazakhstan in November 2023, OECD officials and TIWB experts discussed this issue with representatives of the Ministry of Finance and the State Revenue Committee. Since then, some improvements have been made and Kazakhstan has devoted additional resources to ensuring the attractiveness of these jobs while also employing additional transfer pricing experts.
Outlook
Kazakhstan is determined to pursue its fight against BEPS and has identified the following important action points:
Use of Country-by-Country Reporting Data
Kazakhstan has fully implemented country-by-country reporting; it is now important to use the information gained effectively. Staff need to be trained in the use of country-by-country reports for high-level transfer pricing and BEPS risk assessment, including through the Tax Risk Evaluation and Assessment Tool (TREAT). TREAT was specifically developed by the OECD to help in reading and analysing the data contained in country-bycountry reports.
Implementation of the Two-Pillar Solution
Kazakhstan stands to gain from the implementation of the Two-Pillar Solution. Many MNEs engaged in distribution and marketing activities pay little or no CIT in Kazakhstan because of transfer pricing arrangements. The guidance on Amount B, Pillar One,25 offers a simplified and streamlined approach to transfer pricing for marketing and distribution activities. The guidance on Amount B was included in the Two-Pillar Solution at the specific request of developing countries and is designed with the needs of low-capacity jurisdictions in mind.
The Global Minimum Tax of Pillar Two requires large MNEs to pay an effective tax of at least 15% irrespective of where they are operating. This is critical for Kazakhstan as it can enable the country to raise significant revenues, thereby enhancing DRM. Therefore, Kazakhstan needs to consider the implementation of the Global Anti-Base Erosion (GloBE) Rules26 and/or a Domestic Minimum Top-up Tax to ensure that additional revenues remain in Kazakhstan. Furthermore, the Global Minimum Tax presents a unique opportunity for
Kazakhstan to engage in tax incentive reform, creating more effective incentives to attract real investment in a post-GloBE environment.
Because of Kazakhstan’s extensive tax treaty network, the country also should consider the implementation of the Subject to Tax Rule (STTR) of Pillar Two.27 The STTR was developed to address the priorities of developing countries and is an integral part of achieving a consensus for developing countries. Its implementation will protect Kazakhstan’s right to tax certain intragroup payments where these are subject to a CIT below the nominal rate of 9%. Signing the Multilateral Convention to Facilitate the Implementation of the Pillar Two Subject to Tax Rule28 will allow Kazakhstan to swiftly implement the STTR, modifying its tax treaty network in a synchronised and efficient manner.
Opportunities for Broader Tax Reform
The OECD Tax Policy Review outlines opportunities for broader tax reform in Kazakhstan.29 In view of climate change, Kazakhstan should start raising revenues in sectors other than oil and gas, on which the country relies heavily. Also, Kazakhstan should not focus exclusively on increasing tax rates, but should also broaden the tax base and increase tax compliance. The country should continue its engagement in international dialogue on carbon mitigation approaches, as expressed through its membership in the Inclusive Forum on Carbon Mitigation Approaches.
Conclusion
Kazakhstan’s progress illustrates its role as a regional leader in implementing international tax standards to tackle tax avoidance. Its proactive approach has allowed other countries in the region to benefit from the capacity-building activities that the OECD and other partners have provided to Kazakhstan.
The following lessons have emerged from the capacitybuilding work in Kazakhstan:
1. The correct sequencing of capacity-building support is essential for its success and effectiveness. In the case of Kazakhstan, initial support through the BEPS induction programme helped with the fundamental implementation of the BEPS minimum standards. During the induction phase it became clear that complementary support was needed to increase expertise on transfer pricing in the extractive sector and to reinforce practical auditing skills.
2. In combination, capacity-building and TIWB programmes help to identify areas where training and legislative changes can be key to improving tax policy and administrative capacity, resulting in enhanced DRM. Between 2021 and 2023, USD 211 million of additional tax was assessed through transfer pricing audits in Kazakhstan, including four TIWB supported cases, of which USD 174 million had been collected at the time of this writing.30 In addition, the TIWB programme in Kazakhstan revealed the need for indepth training on financial transactions; in response,
the capacity-building programme offered 30 tailormade workshops on addressing BEPS challenges related to financial transactions.
3. Virtual formats of bilateral capacity-building programmes can provide leverage for a multilateral approach, allowing countries in the region to benefit from training. Since 2019, Kazakhstan has extended numerous invitations to Central Asian neighbours to participate in training sessions on transfer pricing, both in person and virtually (since the COVID-19 pandemic).
4. Sustainable capacity-building depends on appropriate policies to attract and retain qualified tax administration officials. Having faced the challenge of staff loss in the tax administration, Kazakhstan is now developing strategies and policies to ensure staff continuity, including prolonged career opportunities.
Given the past fruitful experience of working with the OECD, we look forward to further co-operation in bringing our tax administration practices in line with generally accepted international standards.
Mr Duysembiev Zhandos Zhumabayevich, Chairman of the State Revenue Committee, Kazakhstan
Notes
1. OECD (2023), Insights on the Business Climate in Kazakhstan, OECD Publishing, Paris, https://doi.org/10.1787/bd780306-en
2. World Bank (2023), Mining sector Diagnostic – Kazakhstan, https://documents.worldbank.org/en/publication/ documents-reports/documentdetail/099081823001539573/ p17674501063760b08b290a4ae6547845d#:~:text=Kazakhstan%20is%20 endowed%20with%20abundant,lead%2C%20and%20eleventh%20for%20gold
3. https://www.worldbank.org/en/country/kazakhstan/overview
4. OECD (2020), OECD Tax Policy Reviews: Kazakhstan 2020, OECD Tax Policy Reviews, OECD Publishing, Paris, https://doi.org/10.1787/872d016c-en
5. In general terms, the idea of the non-oil deficit is to strip out oil revenues from the budget to provide a more realistic measure of the budget deficit in the absence of oil revenues.
6. From 2007 to 2022, the tax-to-GDP ratio in Kazakhstan decreased by 6.3 percentage points, from 26.1% to 19.8%. The highest tax-to-GDP ratio in this period was 27.6% in 2008, and the lowest 14.1% in 2020.
7. OECD Revenue Statistics, Revenue Statistics in Asia and the Pacific 2024 –Kazakhstan, https://www.oecd.org/content/dam/oecd/en/topics/policy-subissues/global-tax-revenues/revenue-statistics-asia-and-pacific-kazakhstan.pdf
8. https://kgd.gov.kz/en
9. https://www.oecd.org/tax/transparency/
10. OECD (2018), Global Forum on Transparency and Exchange of Information for Tax Purposes: Kazakhstan 2018 (Second Round): Peer Review Report on the Exchange of Information on Request, OECD Publishing, Paris, https://doi.org/10.1787/9789264302792-en; OECD (2023), Peer Review of the Automatic Exchange of Financial Account Information 2023 Update, OECD Publishing, Paris, https://doi.org/10.1787/5c9f58ae-en
11. https://oecdgroups.oecd.org/Bodies/ShowBodyView. aspx?BodyID=963&Lang=en
12. https://www.oecd.org/en/topics/base-erosion-and-profit-shifting-beps.html
13. https://www.oecd.org/en/about/news/announcements/2021/10/statementon-a-two-pillar-solution-to-address-the-tax-challenges-arising-from-thedigitalisation-of-the-economy-october-2021.html
14. https://www.oecd.org/en/about/news/announcements/2023/07/outcomestatement-on-the-two-pillar-solution-to-address-the-tax-challenges-arisingfrom-the-digitalisation-of-the-economy-july-2023.html
15. https://www.tiwb.org/
16. According to the OECD’s Rules of Procedure, Participants are invited to attend all meetings of a subsidiary body for an open-ended period and are required to be able and willing to contribute substantially to the fulfilment of the body’s mandate and programme of work through their active participation in its meetings and its work, including by providing the information which the body may require.
17. https://www.oecd.org/en/about/programmes/inclusive-forum-on-carbonmitigation-approaches.html
18. https://www.oecd.org/en/publications/revenue-statistics-in-asia-and-thepacific_5902c320-en.html
19. OECD (2024), Harmful Tax Practices – Peer Review Results, Inclusive Framework on BEPS: Action 5 (Update as of July 2024), https://www.oecd.org/content/dam/ oecd/en/topics/policy-sub-issues/harmful-tax-practices/harmful-tax-practicesconsolidated-peer-review-results-on-preferential-regimes.pdf
20. OECD (2023), Harmful Tax Practices – 2022 Peer Review Reports on the Exchange of Information on Tax Rulings: Inclusive Framework on BEPS: Action 5, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris, https://doi.org/10.1787/22bbeacc-en
21. OECD (2024), Prevention of Tax Treaty Abuse – Sixth Peer Review Report on Treaty Shopping: Inclusive Framework on BEPS: Action 6, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris, https://doi.org/10.1787/36cebf8e-en
22. OECD (2024), Country-by-Country Reporting – Compilation of 2024 Peer Review Reports: Inclusive Framework on BEPS: Action 13, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris, https://doi.org/10.1787/f3d3f36f-en
23. OECD (2021), Making Dispute Resolution More Effective – MAP Peer Review Report, Kazakhstan (Stage 1): Inclusive Framework on BEPS: Action 14, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris, https://doi.org/10.1787/5bb425a9-en
24. OECD (2022), Making Dispute Resolution More Effective – MAP Peer Review Report, Kazakhstan (Stage 2): Inclusive Framework on BEPS: Action 14, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris, https://doi.org/10.1787/34c25884-en
25. OECD (2024), Pillar One - Amount B: Inclusive Framework on BEPS, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris, https://doi.org/10.1787/21ea168b-en
26. OECD (2021), Tax Challenges Arising from the Digitalisation of the Economy –Global Anti-Base Erosion Model Rules (Pillar Two): Inclusive Framework on BEPS, OECD Publishing, Paris, https://doi.org/10.1787/782bac33-en
27. OECD (2023), Tax Challenges Arising from the Digitalisation of the Economy –Subject to Tax Rule (Pillar Two): Inclusive Framework on BEPS, OECD/G20 Base Erosion and Profit Shifting Project, OECD Publishing, Paris, https://doi.org/10.1787/9afd6856-en
28. https://www.oecd.org/en/topics/sub-issues/subject-to-tax-rule/multilateralconvention-to-facilitate-the-implementation-of-the-pillar-two-subject-to-taxrule.html
29. OECD (2020), OECD Tax Policy Reviews: Kazakhstan 2020, OECD Tax Policy Reviews, OECD Publishing, Paris, https://doi.org/10.1787/872d016c-en
30. The difference in assessed and collected tax is due to a lag between the time additional tax is assessed and when the tax due on those assessments is collected from taxpayers.
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