TP Advisory - Transfer Pricing as Part of Business Strategy

Services

Transfer Pricing Strategy

Design and review of intra-group models and methodologies aligned with business structures and regulatory requirements.

Risk Management and Defence

Diagnostic review of transfer pricing frameworks and representation in audits and tax disputes.

Economic Analysis

Benchmarking studies and preparation of economic support for intra-group transactions.

Compliance and Internal Function

Preparation of transfer pricing documentation and reporting, and establishment of internal governance frameworks.

The appropriate format of engagement is determined following a detailed discussion of the assignment.

Discuss Engagement Structure

Why TP Advisory

Partner-Led Engagement

All mandates are led directly by a partner, ensuring responsiveness, sound judgement and clear accountability for the position taken.

Strategic Clarity

Transfer pricing is treated as a component of financial resilience and disciplined tax risk management.

High-Scrutiny Matters

We act on assignments subject to regulatory oversight and requiring rigorous economic substantiation.

International Standard of Analysis

Drawing on extensive Big Four experience, we apply internationally recognised methodologies within an independent advisory framework.

Founder and Partner

Aizhan Sumembaeva

Nearly 20 years of experience in taxation and transfer pricing, including practice with Ernst & Young across Kazakhstan, Russia and Germany
Advising over 100 leading Kazakhstani and international companies across multiple industries
Member of the Kazakhstan Bar Association
Co-Founder and Partner of TP Advisory since 2020

Today, TP Advisory is supported by a team of approximately XX professionals in transfer pricing and taxation, including analysts, researchers and benchmarking specialists, ensuring each mandate is delivered in line with international standards.

Selected Experience

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Frequently Asked Questions

Where cross-border intra-group transactions exist, transfer pricing becomes an element of managed tax risk. As businesses grow, restructure or increase profitability, the level of economic substantiation expected by tax authorities correspondingly increases.

Formal compliance addresses the existence of documentation. A strategic approach assesses whether the model is robust under scrutiny, aligned with the commercial reality of the business and consistent with internationally recognised standards.

Following corporate restructuring, market expansion, changes in functions and risk allocation within the group, introduction of new business lines, or material shifts in profitability.

Yes. A clearly articulated and economically defensible model enhances predictability of the company’s position and reduces exposure to reassessments and prolonged disputes.

Transfer Pricing as
Part of Business Strategy

TP Advisory operates at the intersection of commercial
strategy, economic analysis and regulation.