The Income Tax Transfer Pricing Regulations 2014

The much anticipated Tanzania Transfer Pricing Regulations ("the Regulations") were publicly released in May 2014. The relevant instrument is Government Notice No 27 ("The Income Tax (Transfer Pricing) Regulations, 2014) published on and effective from 7 February 2014.

Since inception the Income Tax Act ("ITA") 2004 has had a requirement that transactions between associates should be undertaken at arms' length (Section 33 ITA 2004).

The Income Tax Regulations 2004 issued shortly after the publication of the ITA 2004 had included a regulation providing the possibility to enter into advance pricing agreements, and had also stated that the transfer pricing section in ITA 2004 "shall be construed in such manner as best secures consistency with the transfer pricing guidelines in the Practice Notes issued by the Commissioner". However, until the recent issue of the Regulations no such guidance had been given.

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