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African Countries Discuss Transfer Pricing

by Lorys Charalambous,, Cyprus

07 July 2011

Within the Africa Tax Administration Forum (ATAF), the tax authorities of several African countries are considering how to collaborate in exchanging information on the transfer pricing practices of multinational companies operating in their countries.

The African tax authorities wish to learn more about the possible risk to their tax bases posed by transfer pricing, and tax officials from five countries – South Africa, Ghana, Tanzania, Zambia and Mozambique – held a recent meeting to consider the issue at ATAF’s offices in Pretoria.

Following the meeting, Logan Wort, ATAF’s executive secretary, reported that the countries had agreed to start talks on a regional tax information exchange agreement, which would allow them to share their data on all types of transfer pricing, including not only the pricing of goods and services, but also the operation of such matters as royalties, and management and procurement fees.

He also said that the representatives at the meeting wanted to be able to examine the possible tax leakages arising if the arms-length principle behind cross-border intra-group transactions is not maintained, while they also discussed the possibility of providing for the secondment of officials between countries on particular transfer pricing matters.

This comprehensive report in our Intelligence Report series examines the global and national landscapes in which companies can use transfer pricing to improve their after-tax returns, including summaries of recent developments in design of the corporate supply train, the usefulness of 'offshore' in international corporate tax planning, and a section covering the spread of DTAAs and CFC laws. It is available in the Lowtax Library at and a description of the report can be seen at
TAGS: South Africa | tax | business | law | Mozambique | agreements | multinationals | transfer pricing | Zambia | Ghana | Tanzania | Africa

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