Algeria Transfer Pricing Documentation Requirements
Algeria requires transfer pricing documentation where a company's turnover or gross assets reach DZD 1 billion and it meets a shareholding test relative to a connected company. A two-stage enforcement process applies, with a 2 percent penalty only after a formal notice goes unanswered, and an online transfer pricing form must be submitted.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
TP documentation Required | Turnover or gross assets ≥ DZD 1bn and a >50% capital or >40% voting-rights link | On request | Preparation deadline The documentation must exist by the date shown and is produced only when the tax authority requests it. Once requested, it must be provided within 15 days. | FR / AR | Yes (2% of transactions after an unanswered formal notice) |
TP form Online
Annual filing | Companies within the transfer pricing obligation | With the annual filing | Submission deadline The documentation must be filed with the tax authority by the date shown. | FR / AR | Yes |
Calculate your exact Algeria deadline
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Scope of the documentation obligation
A company is subject to the documentation requirement where it has annual turnover, excluding tax, or gross assets of at least DZD 1 billion for the year, and it holds, directly or through an intermediary, more than 50 percent of the share capital or more than 40 percent of the voting rights of a connected company, or is held to that extent. Documentation is produced within 15 days of a request, and an online transfer pricing form must be submitted. There is no Country-by-Country reporting obligation in the regime as captured.
Distinctive features of the Algerian regime
The defining feature of the Algerian regime is its two-stage enforcement. In an accounting audit, a failure to present the required documentation, or an incomplete production, first results in a formal notice from the tax authority; only where there is no response, or an incomplete response, to that notice does a penalty apply, set at 2 percent of the amount of the transactions concerned by the missing or incomplete documents, subject to a minimum. This gives the taxpayer an opportunity to cure the deficiency before the penalty bites. The scope test combines a financial threshold with a shareholding test, so both conditions must be met. There is no published safe harbour.
Benchmarking and comparables
Local comparables are preferred, although regional comparables can in some cases be accepted because of a lack of local data. The choice between single-year and multi-year testing is not specified by legislation or administrative doctrine, and neither is the frequency of a fresh search; because of the lack of comparable data, both aggregation and individual testing are accepted in practice. The limitation period is the same as for corporate tax assessments generally, namely four years following the year for which the tax is due.
Frequently asked questions
When does the Algerian 2 percent penalty apply?
Only after a two-stage process. A failure to present documentation in an audit first triggers a formal notice, and the 2 percent penalty applies only where there is no response, or an incomplete response, to that notice.
This guide is an informational research aid prepared by Comp-Press and is not tax or legal advice. Transfer pricing rules change; verify current requirements before relying on them for filing.