PUBLICATIONS

Transfer Pricing in Tanzania: Why Non-Compliance Is No Longer an Option

Transfer Pricing Compliance in Tanzania: Key Takeaways

Transfer pricing is one of the most actively enforced areas of tax law in Tanzania. The Tanzania Revenue Authority has intensified audits on cross-border related-party transactions, and the consequences of non-compliance are severe — including a 100% penalty on any adjusted amount, interest on underpaid tax, and potential VAT exposure.

The regime is anchored in Section 33 of the Income Tax Act and the 2018 Transfer Pricing Regulations, with Tanzania's definition of "associate" notably broader than the OECD standard — capturing exclusive supply arrangements and financing structures even without any equity link.

The single most important compliance obligation is contemporaneous documentation. It must be prepared at the time of the transaction, not after a TRA audit begins. Tanzania's courts have categorically rejected retrospective documentation and retroactive policy adjustments, as confirmed in a line of Court of Appeal decisions running from Atlas Copco (2020) through to the landmark Amadeus Global ruling of March 2026.

Businesses with related-party transactions should conduct a transfer pricing health check, ensure their method selection is properly justified, and consider an Advance Pricing Arrangement with the Commissioner for certainty going forward.

For the full legal analysis, download our complete guide below.