Tanzania Transfer Pricing Documentation Requirements

Scope of the documentation obligation

There is no value threshold for preparing transfer pricing documentation in Tanzania. Every taxpayer with related-party transactions must prepare it by the income tax return filing date, regardless of the amount. Where a taxpayer’s related-party transactions reach TZS 10 billion, the documentation must additionally be submitted alongside the return rather than merely held. Documentation is produced within 30 days of a request.

Distinctive features of the Tanzanian regime

Two features distinguish the Tanzanian regime. The first is the universal preparation duty paired with a submission threshold: all taxpayers must prepare documentation, but only those above TZS 10 billion must file it with the return, which separates the duty to hold documentation from the duty to submit it. The second is the size of the minimum penalty. A failure to submit, or a late submission, attracts a minimum penalty of TZS 52.5 million, a high floor relative to the region that makes timely compliance a material concern. There is no published safe harbour, and there is no Country-by-Country reporting obligation in the regime as captured.

Benchmarking and comparables

Local comparables are preferred but not mandatory. Multi-year testing, preferably over three years, is preferred. There is no requirement to perform a fresh benchmarking study every year, with a fresh search conducted every three years in practice and an annual financial update. The limitation period is five years from the due date for filing the final corporate income tax return, with no limit in cases of fraud, evasion, or gross or wilful neglect.