Worldwide transfer pricing reference guide 2014

Tanzania
Taxing authority and tax law
Taxing authority: Tanzania Revenue Authority (TRA).
Tax law: There are currently no transfer pricing regulations in Tanzania.
Relevant regulations and rulings
Section 33 of the Income Tax Act, 2004 (ITA 2004) emphasizes the arm’s length principle on transactions between associates.
OECD Guidelines treatment
The TRA’s internal manual recognizes the application of the OECD methods in determining the arm’s length pricing.
Priorities/pricing methods
The TRA’s internal manual recognizes the application of the OECD methods in determining the arm’s length pricing.
Transfer pricing penalties
There are no specific transfer pricing penalties. However, Section 33 gives the powers to make adjustments to a transaction that does
not comply with the arm’s length principle.
The law also imposes interest for underpayment of tax (Section 100 of the ITA 2004).
Penalty relief
Currently, there is no penalty relief available in Tanzania.
Documentation requirements
There are no transfer pricing documentation requirements in Tanzania. However, all transactions require supporting documentation.
Documentation deadlines
Not applicable.
Statute of limitations on transfer pricing assessments
No special rules. A general rule of three years applies.
Return disclosures/related party disclosures
The taxpayer is required to disclose the amount of sales, purchases and loans made or received from associates, in and outside of
Tanzania in its tax return.
Transfer pricing-specific returns
Not applicable.
Frequency of tax audit and transfer pricing scrutiny by the tax authority
There are no special transfer pricing audits; intercompany transactions are audited in the general tax audits.
Worldwide transfer pricing reference guide
293