Data points
- Turnover or gross assets that trigger documentation[2]
- XOF 5bn
- Consolidated turnover that triggers a country-by-country report[1]
- XOF 491bn
- Filing date for the master file and local file, for a 31 December year end[1]
- 30 April
- After year end to file the country-by-country report[1]
- 12 months
- Fine for a late or missing country-by-country report[2]
- XOF 25m
- Of undocumented transaction value, per audited year, for ignoring a documentation notice[2]
- 0.5%
- To answer a documentation notice from the tax authority[2]
- 20 days
Senegal collects transfer pricing documentation rather than waiting for an audit to ask for it. The master file and the local file go in with the annual return, so a group that prepared nothing has already missed a dated filing.
The four facts to know:
- Documentation is owed once turnover or gross assets reach XOF 5 billion.
- The master file and the local file are filed with the annual profit and loss return, which falls on 30 April for a 31 December year end.
- A country-by-country report is owed from XOF 491 billion of consolidated turnover, filed electronically within 12 months of year end.
- Fines run to XOF 10 million for a late transfer pricing declaration, XOF 25 million for a late country-by-country report, and 0.5% of undocumented transaction value per audited year.
What transfer pricing documentation does Senegal require?
A master file and a local file, both submitted with the annual profit and loss return. Senegal is a filing regime, not a produce-on-request one, and that is the single thing most foreign parents get wrong about it. The OECD transfer pricing country profile for Senegal[1], last updated in February 2022, confirms the filing obligation but states no revenue threshold for it. The threshold comes from the tax code administered by the Direction Générale des Impôts et des Domaines[2], Senegal's tax authority.
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| Requirement | Senegal rule in 2026 | Source |
|---|---|---|
| Master file | Required, filed with the annual return | Direction Générale des Impôts et des Domaines, Senegal |
| Local file | Required, filed with the annual return | Direction Générale des Impôts et des Domaines, Senegal |
| Documentation threshold | XOF 5 billion in turnover or gross assets | Direction Générale des Impôts et des Domaines, Senegal |
| Country-by-country report | From XOF 491 billion of consolidated turnover | OECD |
| Country-by-country deadline | Within 12 months of year end, filed electronically | OECD |
| Country-by-country notification | Not confirmed | OECD |
| Penalties | XOF 10 million, XOF 25 million, or 0.5% of undocumented value | Direction Générale des Impôts et des Domaines, Senegal |
| Language | Not confirmed | OECD |
XOF is the West African CFA franc, Senegal's currency. One caution on dates: the profile above predates Senegal's own transfer pricing Instruction, which was still awaiting signature when the profile was written. Confirm the current Instruction before you rely on a 2022 position.
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When is Senegal transfer pricing documentation due?
With the annual profit and loss return, which falls on 30 April for a 31 December year end. The country-by-country report runs on its own clock: 12 months after the financial year end, filed electronically.
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| Obligation | Deadline | Source |
|---|---|---|
| Master file and local file | With the annual return, 30 April for a 31 December year end | OECD |
| Country-by-country report | Within 12 months after the financial year end, electronic | OECD |
| Response to a documentation notice | 20 days | Direction Générale des Impôts et des Domaines, Senegal |
What language must the documentation be in?
Not confirmed. No published source states a language rule for Senegalese transfer pricing documentation, so this page does not assert one. Settle it with the tax authority before you file.
Does Senegal require country-by-country reporting?
Yes, from XOF 491 billion of consolidated turnover excluding tax in the preceding year. That is Senegal's version of the EUR 750 million standard used across the OECD and G20 Inclusive Framework on base erosion and profit shifting[3], which Senegal joined.
The report is owed by a Senegal-established ultimate parent that prepares consolidated accounts, controls at least one entity or branch outside Senegal, and is not itself held by another filer. A separate notification requirement is not confirmed, which is an open item rather than a clearance. Do not read the silence as an exemption.
What are the penalties for missing Senegal transfer pricing documentation?
Three fixed amounts, set in the tax code and still in force for 2026. Because they are statutory rather than discretionary, you can plan around them instead of guessing. Senegalese law offers no compliance incentive that reduces them.
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| Failure | Penalty | Source |
|---|---|---|
| Late or missing annual transfer pricing declaration | XOF 10 million | Direction Générale des Impôts et des Domaines, Senegal |
| Late or missing country-by-country report | XOF 25 million | Direction Générale des Impôts et des Domaines, Senegal |
| No answer, or a partial answer, to a 20-day documentation notice | 0.5% of undocumented transaction value, per audited year | Direction Générale des Impôts et des Domaines, Senegal |
Because documentation is filed rather than held, a missing file is a dated, visible failure from the day the return goes in. There is no quiet period in which to assemble one.
How do Senegal's rules differ from the OECD baseline?
Senegal follows the OECD guidelines largely, and the gaps sit in how documentation is handled and which comparables count.
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| Feature | Senegal | OECD baseline | Source |
|---|---|---|---|
| Documentation handling | Filed with the annual return | Often kept and produced on request | OECD |
| Comparables | Local comparables preferred | No local preference | OECD |
| Secret comparables | Not used | Not used | OECD |
| Safe harbours | None confirmed | Optional under the guidelines | OECD |
Can you get an advance pricing agreement in Senegal?
Yes. Unilateral, bilateral and multilateral advance pricing agreements are all available. No filing steps or timelines are published, so expect the procedure to be agreed case by case with the tax authority. An agreement still rests on a defensible comparables set, which is the work that takes the time.
How we help with Senegal transfer pricing
Senegal gives you one date and no grace period, so the file has to exist before the return does. We build the benchmarking and the functional analysis, draft the master file and the local file, and hand them over in time to go in with the annual return. See how our transfer pricing software works.
Book a demo to get a Senegal documentation exposure review before your next annual return.
Official sources
3 sources
- 1.OECD. Transfer pricing country profile: Senegal (February 2022)
- 2.Direction Générale des Impôts et des Domaines, Senegal. Senegal's tax authority, which administers the General Tax Code
- 3.OECD. OECD/G20 Inclusive Framework on BEPS, composition (28 May 2024)
Article by
Logan Jackonis
Head of Services & Operations, Commenda
Logan leads Commenda’s Services and Operations team, helping controllers, heads of tax, and finance leaders navigate international expansion. He built a global expert network across 70 countries and previously worked in management consulting across the Middle East and Southeast Asia.
Disclaimer: Commenda and its affiliates do not provide tax, accounting, or legal advice. This material has been prepared for informational purposes only, and is not intended to provide or be relied on for tax, accounting, or legal advice. You should consult your own tax, accounting, and legal advisors before engaging in any related activities or transactions.
