Worldwide transfer pricing reference guide 2014

Algeria (continued)
Documentation requirements
According to Article 04 of the Decree dated 12 April 2012, the transfer pricing documentation must contain:
Basic documentation of general information concerning the group
• A general description of the activity performed, including changes that occurred during the fiscal year
• A description of the organizational structure and the nature of the relations that link the foreign company and/or the Algerian
company to the other Algerian company (organization chart, direct and indirect capital ties, voting rights, shareholders’ agreement,
business flows, etc.)
• A general description of the functions performed, risks incurred and assets of each related company
• A general description of the group’s transfer pricing policy
Company-specific documentation
• A description of the company, the activities it performs and the nature of the transactions it is engaged in, including the changes that
have occurred during the FY
• A description of the transactions performed with other related companies, including the nature of the flows of transaction and their
amounts, including royalties — may be presented globally by transaction type
• ►Copies of the statutory auditors’ annual reports and the financial statements for the FY concerned
• A list of the main intangible assets held (patents, trademarks, trade names, know-how, etc.) in relation to the company
• Copies of all agreements between the companies concerned
• Financial information, overhead and administrative expenses, and research and development costs
• Description and justification of the arm’s length nature of the transfer pricing method chosen (OECD standards)
• For the documentary requirements, companies concerned may provide any other documentation that is likely to provide clarification to
the tax administration
The entities concerned are required to provide the following information
• De jure or de facto legal entities or groups of legal entities working in the field of hydrocarbon activities and their subsidiaries as
provided by law
• Joint stock companies and partnerships who have opted for the tax regime for joint stock companies whose sales at the close of the
financial year are greater than or equal to DZD100 million
• De jure or de facto groups of companies, where the annual sales of any one of the member companies are greater than or equal to
DZD100 million
• Companies established in Algeria that are members of foreign groups (whatever Algerian tax regime applies)
Documentation deadlines
The transfer pricing documentation must be filed at the DGE along with the annual tax return (no later than 30 April every year).
Companies not listed above have to prepare the same documentation in order to justify the transfer pricing policy in the framework of a
tax audit.
Statute of limitations on transfer pricing assessments
The statute of limitations for transfer pricing adjustments is the same for all Algerian corporate tax assessments, i.e., four years
following the year on which the tax is due.
Worldwide transfer pricing reference guide
14