Worldwide transfer pricing reference guide 2014

Republic of Congo (continued)
Documentation deadlines
Transfer pricing documentation must be kept available at any time. In case of a tax audit, it must be provided from the starting date of
the audit. Otherwise, the tax inspectors will summon within the next 30 days.
Various sanctions related to the non-completion of this requirement have not been specified yet.
Statute of limitations on transfer pricing assessments
In the absence of specific rules in this area, it is most likely that the general statute of limitations of four years from the date of the
transaction in question, would apply.
Return disclosures/related party disclosures
All information/supporting documents/data-entries on various transactions with related parties must be disclosed.
Transfer pricing-specific returns
There are no specific transfer pricing returns for tax payers.
Frequency of tax audit and transfer pricing scrutiny by the tax authority
The likelihood of occurrence of tax audits is low. In practice, annual tax audits are scheduled every two years. The likelihood of a transfer
pricing review as part of a general tax audit is low. As of January 2014, Congo has not experienced audits on transfer pricing issues.
APA opportunity
Not applicable.
Expected reaction to OECD Report on BEPS
There has not been any reaction from the tax authorities until January 2014.
Worldwide transfer pricing reference guide
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