We're a small subsidiary. Does transfer pricing really apply?

Audits & Disputes

Transfer Pricing & Related-Party Compliance

Arm's-length policies, documentation and disclosures for transactions with related parties.

Key facts

New penalty (2026)Greater of 30% of the adjustment or 100% of the shortfall

Audit focusTP is a current TRA audit priority

StandardArm's-length principle

Transfer pricing is a top TRA audit focus, and the Finance Act 2026 raised the stakes: the penalty is now the greater of 30% of the adjustment or 100% of the tax shortfall. If your Tanzanian business buys from, sells to, borrows from or pays fees to related companies, you need defensible policies and contemporaneous documentation.

What's included

TP risk review

Mapping related-party transactions and identifying exposure.

Policy design

Arm's-length pricing methods for goods, services, royalties and financing.

Documentation

Local file documentation aligned with Tanzanian regulations and group master files.

Annual disclosures

Related-party disclosures in your income tax return.

Intra-group services

Evidence that management and technical fees are real, beneficial and correctly priced.

Audit defence

Supporting your position in TRA transfer-pricing audits.

How it works

1Transaction mapping
2Functional analysis
3Benchmarking
4Policy & agreements
5Documentation
6Annual update

Frequently asked

Yes. The rules apply to controlled transactions regardless of company size, although the depth of documentation can be proportionate. Even one management fee or loan from the parent should be supported.

Free consultation

Talk to a transfer pricing consultant.

Share a few details and we'll come prepared, with the documents you need and a clear fixed fee.

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Company name

Type of business

Annual turnover

Your business is

Tanzanian-owned Foreign-owned

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Confidential. We reply within one business day.