East Africa has become one of the most active transfer pricing regions on the continent. Revenue authorities are investing in specialist units, and groups operating across the region are seeing more audits, more information requests and faster enforcement.
A shifting enforcement environment
Several East African authorities now run dedicated international tax and transfer pricing teams, supported by improved access to group data through Country-by-Country reporting and exchange-of-information networks.
What is drawing attention
- Management and service fees, authorities test both the benefit received and the basis of the charge.
- Commodity and distribution margins, particularly in agriculture, mining and consumer goods.
- Intra-group financing, interest rates and thin capitalisation.
Staying ahead
Groups that maintain current documentation and consistent regional policies are far better placed to respond when an audit begins.
“Across East Africa the direction of travel is clear: more scrutiny, more data and less tolerance for documentation prepared after the fact.”
How TPTAX can help
We provide research, training and limited scope advisory support on regional transfer pricing and audit readiness across Africa and the Middle East (GCC countries). Get in touch to discuss your group's position.