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Income tax - Transfer pricing

Republic of Burundi

Currently there are no transfer pricing regulations



Republic of Kenya

The Income Tax Act requires transactions between resident companies and their related non-residents to be at arm’s length.


The Minister for Finance in the 2006 budget introduced the Income Tax (Transfer Pricing) Rules.


The Finance Act 2012 enacted provisions to give effect to Tax Information Exchange Agreements (TIEA) which the Kenyan government intends to enter with other governments.



Republic of Rwanda

The Rwandan law on direct taxes on income stipulates that where conditions are made or imposed between related persons carrying out their commercial relationship which differ from those which would be applied between independent persons, the Commissioner General, may direct that the income of one or more of those related persons be adjusted to include profits that would have been made if they operated as independent persons.


The tax legislation empowers Commissioner General to make arrangements in advance with persons carrying out business with related persons to ensure efficient application of the Transfer Pricing provision.



United Republic of Tanzania

The Income Tax Act 2004 contains a provision which deals with transfer pricing.


The provision refers to the arm’s length principle, a requirement which applies not only to transactions with non-resident associates but also to transactions with resident associates.



Republic of Uganda

Transfer pricing regulations apply effective 1 July 2011. The regulations are modelled on the OECD Model Tax Convention.


Businesses in Uganda are now required to determine their income and expenditures arising from transactions with related parties in a manner that reflects the arms’ length principle.


East African Community
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United Republic of Tanzania

Tel: +255 (0)27 216 2100
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