Section 7 (1) of Tax Administration (Transfer Pricing) Regulation Cap. 439 requires every person participating in a controlled transactions shall prepare contemporaneous Transfer Pricing documentation
The penalty for not having the transfer pricing documentation in place is imprisonment for a term not exceeding six months, a fine not less than TZS 50 million (approx. 19,231 US dollars at the exchange rate of TZS 2,600/US dollar) or both. Violation of the Regulations attracts a penalty of 100% of the underpaid tax and resulting interest thereon.
The main aim of the Transfer Price regulations are to manage and minimize profit shifting by companies operating in Tanzania that have transactions with associates entities established outsides Tanzania and especially those in low tax jurisdictions or tax havens.
Transfer Pricing applies to transactions between related entities which include
Note: The transactions covered under the Tanzania TP Regulations include cross border or domestic transactions.
Tanzania TP Regulations require for an entity with related party transactions to prepare contemporaneous TP documentation. Where the related party transactions during the year exceeds the threshold of TZS 10 billion, it is mandatorily required to submit the document together with the entity’s final return of income.
Entity having related party transactions below the threshold are required to prepare TP documentation prior to the date of filing final return of income. The entity is supposed to submit the document to TRA within 30 days upon request. Failure to comply with the submission of policy will trigger a penalty of TZS 52.5 million.
Section 7 (2) of Tax Administration (Transfer Pricing) Regulation Cap. 439 highlights what contemporaneous TP document should include the following...
The TRA have a right to reject TP documentation where it lacks any of the above requirement or fails to establish the arm’s length price that they deem fit using the most appropriate TP method for any related party transaction. Where the TRA make any adjustments, a penalty of 100% of the adjustment is imposed
If you are required to prepare transfer pricing documentation, do not file your 2025 return of income until the documentation is in place. To avoid unnecessary penalties, engage a reliable and trusted professional team to prepare transfer pricing documentation that can withstand scrutiny by TRA.
Getting started is easy, send the message “CLIENT” to WhatsApp No: 0752 187 434 or email: info@halaconsultants.co.tz
The penalty for not having the transfer pricing documentation in place is imprisonment for a term not exceeding six months, a fine not less than TZS 50 million (approx. 19,231 US dollars at the exchange rate of TZS 2,600/US dollar) or both. Violation of the Regulations attracts a penalty of 100% of the underpaid tax and resulting interest thereon.
The main aim of the Transfer Price regulations are to manage and minimize profit shifting by companies operating in Tanzania that have transactions with associates entities established outsides Tanzania and especially those in low tax jurisdictions or tax havens.
Transfer Pricing applies to transactions between related entities which include
Note: The transactions covered under the Tanzania TP Regulations include cross border or domestic transactions.
Tanzania TP Regulations require for an entity with related party transactions to prepare contemporaneous TP documentation. Where the related party transactions during the year exceeds the threshold of TZS 10 billion, it is mandatorily required to submit the document together with the entity’s final return of income.
Entity having related party transactions below the threshold are required to prepare TP documentation prior to the date of filing final return of income. The entity is supposed to submit the document to TRA within 30 days upon request. Failure to comply with the submission of policy will trigger a penalty of TZS 52.5 million.
Section 7 (2) of Tax Administration (Transfer Pricing) Regulation Cap. 439 highlights what contemporaneous TP document should include the following...
The TRA have a right to reject TP documentation where it lacks any of the above requirement or fails to establish the arm’s length price that they deem fit using the most appropriate TP method for any related party transaction. Where the TRA make any adjustments, a penalty of 100% of the adjustment is imposed
If you are required to prepare transfer pricing documentation, do not file your 2025 return of income until the documentation is in place. To avoid unnecessary penalties, engage a reliable and trusted professional team to prepare transfer pricing documentation that can withstand scrutiny by TRA.
Getting started is easy, send the message “CLIENT” to WhatsApp No: 0752 187 434 or email: info@halaconsultants.co.tz
