Group taxation is not permitted in Kyrgyzstan.
While there is no special law on transfer pricing in Kyrgyzstan, rules on transfer pricing are found in the Tax Code. The general transfer pricing provisions set in the Tax Code do not follow Organisation for Economic Co-operation and Development (OECD) guidelines (thus, no advance pricing agreement [APA] mechanism is provided). According to the Kyrgyz transfer pricing regulations, the tax authorities are empowered to determine the value of the following transactions:
- Transfers between related parties.
- Barter transactions.
- Cross-border transactions.
Provisions to the transfer pricing regulations were also developed granting the tax authorities the right to carry out transfer pricing controls on operations with goods for which the minimum target price has been established.
There are no thin capitalisation limitations under the Kyrgyzstan Tax Code.
Controlled foreign companies (CFCs)
There are no provisions for CFCs in Kyrgyzstan.