Data points
- Aggregate controlled transactions that trigger filing with the income tax return[1]
- TZS 10bn
- To produce documentation after a written request, with no extension[1]
- 30 days
- Record retention, or longer while an objection or appeal is open[4]
- 5 years
- Jurisdictions in the Inclusive Framework, which does not include Tanzania[3]
- 148
- Percentile range applied where more than four comparables are available[1]
- 35th to 60th
- When the current transfer pricing regulations took effect[1]
- Apr 27, 2018
Tanzania splits one obligation into two. Everyone with related-party dealings has to hold documentation. Only the larger taxpayers have to hand it in. Groups that read "threshold" as "exemption" get the first half wrong.
The four facts to know:
- Documentation is required from every person with controlled transactions, and it must exist by the income tax return filing date.
- You file it with the return once aggregate controlled transactions reach TZS 10 billion in a year of income.
- Below that figure you keep it and produce it within 30 days of a written request. No extension is granted once the notice issues.
- Records are kept for five years, or longer while an objection or appeal is open. Documentation is in Swahili or English.
What transfer pricing documentation does Tanzania require?
Contemporaneous documentation from every person with controlled transactions, filed with the income tax return above the threshold and produced on request below it. The duty comes from Tanzania's 2018 transfer pricing regulations[1], which took effect on 27 April 2018 and replaced the 2014 set. TZS is the Tanzanian shilling.
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| Requirement | Rule in 2026 | Source |
|---|---|---|
| Documentation | Contemporaneous documentation for every person with controlled transactions | Tanzania Revenue Authority |
| Filing threshold | File with the income tax return at TZS 10 billion of aggregate controlled transactions | Tanzania Revenue Authority |
| Below the threshold | Prepare, keep, and produce within 30 days of a request | Tanzania Revenue Authority |
| Language | Swahili or English | Tanzania Revenue Authority |
| Record retention | Five years, or longer while an objection or appeal is open | Tanzania Revenue Authority |
| Country-by-country reporting | No confirmed domestic regime. Tanzania sits outside the Inclusive Framework | OECD |
Who do Tanzania's transfer pricing rules apply to?
Any Tanzanian entity that transacts with associates, whether the group is foreign or domestic. The arm's length rule and the Commissioner's power to adjust a price both sit in the Income Tax Act published by the Tanzania Revenue Authority[2]. A foreign parent is caught through its Tanzanian subsidiary, which holds the documentation duty and the penalty exposure.
The exact ownership percentage that makes two parties associates is not confirmed from a primary source, so this page states no figure. Do not import a 25% or 50% default from another country's rules, because the Tanzanian definition is a control test rather than a single percentage.
Do you need a master file in Tanzania?
Not as a named filing. The Tanzania Revenue Authority transfer pricing guidelines do not use the words master file or local file anywhere. Group-level information sits inside the general documentation duty, and no standalone master file deliverable is confirmed in the authority's own sources.
Treat the master file as a concept rather than a Tanzanian filing. If your group already prepares one, keep it available to the Tanzanian entity, because the authority can ask that entity for group-level information and it has 30 days to answer.
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What is the Tanzania documentation filing threshold?
TZS 10 billion of aggregate controlled transactions in a year of income. At or above it, you file the documentation with the income tax return. Below it, the documentation must still exist by the return due date, and you produce it within 30 days of a written request from the Commissioner.
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| Position | Obligation | Deadline in 2026 | Source |
|---|---|---|---|
| At or above TZS 10 billion of controlled transactions | File documentation with the income tax return | With the return, and contemporaneous | Tanzania Revenue Authority |
| Below TZS 10 billion | Prepare and keep, then produce on request | Within 30 days of a written request, no extension | Tanzania Revenue Authority |
| Record retention | Hold the file and its underlying records | Five years, or longer while an objection or appeal is open | Tanzania Revenue Authority |
The authority's guidelines confirm that the TZS 10 billion figure is the value of all controlled transactions in a particular year of income, not a single transaction. At exchange rates around TZS 2,500 to TZS 2,700 to the US dollar in 2026, that is roughly USD 3.7 million to USD 4.0 million.
Does Tanzania require country-by-country reporting?
No confirmed filing or notification regime exists in the tax authority's own sources. Tanzania is not a member of the OECD Inclusive Framework on base erosion and profit shifting, per the OECD Inclusive Framework composition list[3] of 148 jurisdictions updated December 2025. The country-by-country minimum standard therefore does not bind Tanzania by framework commitment.
Two consequences follow for a foreign parent. Do not assume a notification deadline modelled on an EU or OECD member. And do not assume the Tanzanian authority will receive your group's report through automatic exchange, because it will not. The Tanzanian entity is the authority's channel for group data.
Does Tanzania have a transfer pricing disclosure form?
No standalone form or return schedule is confirmed in the tax authority's sources. The obligation is the documentation itself, filed with the income tax return above the TZS 10 billion threshold. This page names no form rather than guess at one.
What language must Tanzania transfer pricing documentation be in?
Swahili or English, the two official languages, and it must be kept inside Tanzania. A document in any other language has to be translated by a translator the Commissioner approves.
English on its own is accepted. You do not need a Swahili version alongside it, which makes Tanzania easier on language than most of its neighbours.
What are the penalties for missing transfer pricing documentation in Tanzania?
A documentation default is a penalised offence, enforced through the compounding of offences procedure in the Tax Administration Act published by the Tanzania Revenue Authority[4]. The specific amounts are not confirmed from a primary source and this page does not quote them. They sit in that Act rather than in the transfer pricing regulations.
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| Breach | Consequence in 2026 | Source |
|---|---|---|
| Documentation default | Penalty applies. The amount is not confirmed from a primary source | Tanzania Revenue Authority |
| No response to a written notice | Compounding of offences, escalating to criminal measures | Tanzania Revenue Authority |
| Non-arm's length pricing | The Commissioner adjusts the Tanzanian taxable profit | Tanzania Revenue Authority |
The adjustment is usually the bigger number. Failing to answer a notice at all can escalate beyond a fine to criminal measures, which is the reason the 30-day window matters more than its size suggests.
What is a foreign parent exposed to in Tanzania?
The parent is exposed through the Tanzanian entity, which holds the file and takes the penalty. The authority can ask that entity for group-level information and give it 30 days, with no extension, and there is no exchange network that would let the authority get the data another way.
Pricing risk flows up as well. An adjustment raises Tanzanian taxable profit, and if the parent jurisdiction grants no corresponding relief, the group is taxed twice on the same margin.
How do Tanzania's rules differ from the OECD baseline?
Tanzania applies the three-tier structure in substance without using its labels, and it sets its own comparables rules. Internal comparables are preferred over external ones. With more than four comparables the range runs from the 35th to the 60th percentile; with four or fewer, the average applies.
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| Dimension | OECD baseline | Tanzania in 2026 |
|---|---|---|
| Inclusive Framework | Member | Not a member |
| Document labels | Master file, local file, country-by-country report | A documentation duty, with no master or local file labels |
| Country-by-country notification | Required under the minimum standard | No confirmed regime |
| Filing trigger | Often revenue based | TZS 10 billion of controlled transactions |
| Comparables | Varies by country | Internal preferred. Over four comparables, the 35th to 60th percentile. Four or fewer, the average |
The guidelines behind those rules took effect on 1 July 2020, issued under the 2018 regulations.
Can you get an advance pricing agreement in Tanzania?
Yes, unilateral, bilateral and multilateral. Terms generally run three to five years, and rollback to earlier periods is possible where the underlying assumptions still hold. The process starts with a pre-filing meeting with the tax authority.
How we help with Tanzania transfer pricing
Tanzania's risk is readiness, not paperwork volume. A request arrives, the clock is 30 days, and there is no extension. We map your Tanzanian entity's controlled transactions against the TZS 10 billion filing trigger, build the benchmarking and functional analysis to the authority's own comparables rules, and keep the file contemporaneous so it is ready before a notice lands. See how our transfer pricing software works.
Book a demo to map your Tanzania documentation obligations before the return deadline.
Official sources
4 sources
- 1.Tanzania Legal Information Institute. Tax Administration (Transfer Pricing) Regulations, 2018
- 2.Tanzania Revenue Authority. Income Tax Act (arm's length rule and the Commissioner's adjustment power)
- 3.OECD. Inclusive Framework on BEPS composition list (updated December 2025)
- 4.Tanzania Revenue Authority. Tax Administration Act (compounding of offences and record retention)
Article by
Sam Suechting
Head of Product, Commenda
Sam is a seasoned expert in sales tax, leading Commenda's effort to build the worlds most comprehensive database of global tax rules and business regulations. At Silverhaze Partners, he worked in early-stage venture capital, where he saw firsthand how tax complexity and regulatory friction hold back startups from scaling internationally. That experience now powers his work at Commenda-bringing clarity, precision, and real-world insight to one of the most frustrating parts of doing business globally.
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.
