Transfer Pricing Africa Landscape

Thriving Economies and Multinational Players

Fueled by pivotal sectors like agriculture, mining, healthcare, and banking, this growth offers great potential while also exposing these nations to potential profit-shifting schemes by multinational enterprises.

Vitality of Transfer Pricing

Tackling these potential profit-shifting arrangements requires multinational enterprises to align the conditions of their intercompany transactions with those agreed by independent enterprises for comparable activities, commonly known as the arm's length price.

Influence of OECD Guidelines

While many African countries look to the OECD's Transfer Pricing Guidelines, understanding the unique domestic transfer pricing rules for each country is crucial. These regulations cover taxpayers' obligations, penalties for non-compliance, applicable pricing methodologies, and other country-specific requirements. 

Grant Thornton Africa Tax Transfer Landscape Guide 2023/2024

 The Grant Thornton Africa Transfer Pricing Landscape Guide 2023/2024 provides a comprehensive overview of the transfer pricing landscape in various African countries, covering:

• Country-specific transfer pricing regulations.
• Documentation requirements and obligations for the local file, Master file, and Country-by-Country report.
• Relevant non-compliance or administrative penalties.
• Risk areas commonly challenged by tax authorities.
• OECD membership status of the country and the possibility for taxpayers to rely on the guidance provided in the OECD Guidelines.
• Guidance on conducting economic analysis and demonstrating the arm's length nature of transactions.
• The availability of an Advance Pricing Agreement program and dispute avoidance/resolution processes.

By leveraging the insights available in this guide, multinational enterprises and taxpayers can effectively navigate the intricate landscape of transfer pricing in African countries and ensure compliance with the specific requirements of each nation.