Papua New Guinea Transfer Pricing Documentation Requirements
Papua New Guinea requires transfer pricing documentation proportionate to the nature and complexity of a taxpayer's international dealings. The documentation is not generally lodged with the return, exposure arises through adjustment rather than a documentation fine, and there is generally no statute of limitations for transfer pricing adjustments.
Requirements at a glance
| Requirement | Threshold | Deadline | Deadline type | Language | Penalty |
|---|---|---|---|---|---|
TP documentation Required | Taxpayers with international related-party dealings (proportionate to complexity) | 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. | EN | Adjustment-based (no non-lodgment penalty other than management fees) |
CbC report Required | Group revenue ≥ PGK 2,300m | 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 |
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Scope of the documentation obligation
Papua New Guinea requires documentation supporting the arm’s length nature of a taxpayer’s international related-party dealings. The tax authority recognises that preparing documentation can be time-consuming and costly, and does not expect taxpayers to incur compliance costs disproportionate to the nature, scope, and complexity of their international agreements, so a proportionality principle governs the depth required. The documentation is not generally lodged with the corporate income tax return, other than for management fees, and is produced on request.
Distinctive features of the regime
Two features distinguish the regime. The first is the absence of a non-lodgment penalty: because the documentation is not generally required to be lodged, no penalty applies for non-submission, and the real exposure is a transfer pricing adjustment and consequent penalties on any underpaid tax where the authority considers the dealings not to be at arm’s length. The second is the absence of a statute of limitations for transfer pricing adjustments, which means there is generally no fixed time bar on the authority revisiting a taxpayer’s transfer pricing position. There is no published safe harbour.
Benchmarking and comparables
Because limited local data is available, the use of regional data is acceptable with appropriate adjustments for local conditions. Multi-year data analysis should be used, per the relevant circular. There is no specific guidance on the frequency of a fresh search; following the OECD Guidelines, prior-year data may be used where it is reasonable to conclude that conditions have not changed. There is generally no statute of limitations for transfer pricing adjustments.
Frequently asked questions
Is there a time limit on transfer pricing adjustments in Papua New Guinea?
There is generally no statute of limitations for transfer pricing adjustments, so there is no fixed time bar on the tax authority revisiting a taxpayer's transfer pricing position.
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.