Gabon Transfer Pricing Documentation Requirements
Gabon requires a Master File and Local File from taxpayers with intragroup transactions, produced within 60 days of a request. Non-filing within the legal deadlines attracts a penalty of 5 percent of all intragroup transactions, capped at XAF 65 million per fiscal year.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
Master File Required | Taxpayers with intragroup transactions | 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 60 days. | FR | Yes (5% of intragroup transactions, capped at XAF 65m) |
Local File Required | Taxpayers with intragroup transactions | By tax return filing date | 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 60 days. | FR | Yes (5% of intragroup transactions, capped at XAF 65m) |
CbC report Required | Group revenue ≥ XAF 491,968m | 12 months after fiscal year-end | Submission deadline The Country-by-Country report is filed by the group's ultimate parent entity; a local notification identifying the reporting entity is filed separately. | — | Yes |
Calculate your exact Gabon deadline
Enter your entity’s fiscal year-end to return your exact Gabon preparation or filing date. Available without registration.
Scope of the documentation obligation
Gabon requires a Master File and Local File from taxpayers engaged in intragroup transactions. The documentation is produced within 60 days of a request. The captured rules do not set a separate value threshold for the documentation obligation, so the requirement attaches to the existence of intragroup dealings.
Distinctive features of the Gabonese regime
The defining feature of the Gabonese regime is the structure of its penalty, which is geared to the value of intragroup transactions but capped. A failure to file the Master File or Local File within the legal deadlines attracts a penalty of 5 percent of all intragroup transactions, subject to a ceiling of XAF 65 million per fiscal year, so the consequence scales with the size of the dealings up to a fixed maximum. Documentation is prepared in French. As several practice points are not captured in the available rules, the benchmarking guidance below follows the OECD framework that Gabon applies.
Benchmarking and comparables
Gabon follows the OECD approach to documentation and comparability. Detailed local practice on the choice between local and foreign comparables, on single-year versus multi-year testing, and on the frequency of fresh searches is applied consistently with the OECD framework, and a taxpayer is expected to support its pricing with a comparability analysis on that basis.
Frequently asked questions
How is the Gabonese documentation penalty calculated?
A failure to file the Master File or Local File within the legal deadlines attracts 5 percent of all intragroup transactions, capped at XAF 65 million per fiscal year.
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.