Worldwide transfer pricing reference guide 2014

Algeria (continued)
Return disclosures/related party disclosures
In the framework of a tax audit during which tax inspectors are entitled to audit possible infringement of the arm’s length principle with
related parties (intercompany transactions), i.e., the existence of commercial and/or financial relationship that differs from those which
would be made between independent enterprises.
Transfer pricing–specific returns
Not applicable.
Frequency of tax audit and transfer pricing scrutiny by the tax authority
The likelihood of a tax audit in Algeria is high for domestic and foreign companies. Usually, a tax audit covers a three-to four-year period
on a continuous basis.
Tax audit and tax reassessment related to transfer pricing are more and more frequent. Field auditors are not always applying transfer
pricing concepts and, as a result, the adjustments are sometimes not only grounded on OECD Guidelines. It is also worth mentioning that
there are currently no local financial public databases at disposition of tax authorities or companies.
APA opportunity
The Algerian tax legislation does not provide any specific APA procedure. However, a binding tax ruling procedure was introduced in the
Algerian tax procedure code recently (for companies’ eligible, to the DGE). This procedure could in theory cover transfer pricing.
Expected reaction to OECD Report on BEPS
As of January 2014, the tax authorities have not reacted to BEPS.
Worldwide transfer pricing reference guide
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