Data points
- Turnover excluding VAT that triggers the annual transfer pricing declaration[2]
- TND 200m
- Transaction category value that must be itemised inside the declaration[2]
- TND 100,000
- To produce the master and local files after a formal notice[3]
- 40 days
- Floor on the documentation penalty, for each fiscal year under audit[3]
- TND 50,000
- Consolidated revenue that triggers country-by-country reporting[4]
- TND 1,636m
- After the fiscal year end, to file the country-by-country report[5]
- 12 months
- Capital or voting rights above which two enterprises are related[1]
- 50%
Tunisia runs three obligations that are easy to confuse. One form is filed. One set of files is held and handed over on demand. One report applies only to Tunisian-headquartered groups.
The four facts to know:
- A Tunisian entity related to a foreign group member files an annual transfer pricing declaration with its corporate income tax return once turnover excluding VAT reaches TND 200 million.
- Inside that declaration you list every related-party transaction category whose annual amount excluding tax reaches TND 100,000.
- Master and local files are held, not filed. You produce them within 40 days of a formal notice during an audit.
- Failing to produce them costs 0.5% of the transactions concerned, with a floor of TND 50,000 for each fiscal year under audit.
Who is caught by Tunisia's transfer pricing rules?
A Tunisian entity is caught when it is related to a foreign group member and its annual turnover excluding VAT reaches TND 200 million. Two enterprises are related when one holds, directly or through an interposed person, more than 50% of the other's share capital or voting rights, or when both sit under common control.
Judge the test from the parent's side. If your group owns more than half of the Tunisian entity, or the entity and your group answer to the same ultimate owner, it is dependent for these purposes. The ownership test and the regime's design are set out in the OECD transfer pricing country profile for Tunisia[1].
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| Question | Answer in 2026 | Source |
|---|---|---|
| Who is caught | Tunisian entities related to a foreign group member, with turnover excluding VAT of TND 200 million or more | Direction Generale des Impots, Tunisia |
| What must exist | An annual declaration, filed. Master and local files, held and produced within 40 days of a formal notice | Direction Generale des Impots, Tunisia |
| When | The declaration with the corporate income tax return. The country-by-country report within 12 months of the fiscal year end | Direction Generale des Impots, Tunisia |
| What a gap costs | Documentation: 0.5% of transactions, floor TND 50,000 a year. Country-by-country: TND 50,000, plus TND 100 per item capped at TND 10,000 | Direction Generale des Impots, Tunisia |
What is Tunisia's annual transfer pricing declaration?
A form filed with the corporate income tax return by any Tunisian entity in a multinational group that transacts with foreign related parties and has turnover excluding VAT of TND 200 million or more. It is filed electronically, on the same deadline as the return itself. Within it, you itemise every related-party transaction category whose total annual amount excluding tax reaches TND 100,000, as set out in the transfer pricing declaration form published by the Ministry of Finance[2].
Keep the three obligations apart. The declaration is a filed form. The master and local files are documentation held and produced on request. The country-by-country report is a separate filing for large Tunisian-parented groups only.
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What is the transfer pricing documentation threshold in Tunisia?
The confirmed, primary-sourced trigger is turnover excluding VAT of TND 200 million or more, and it is the trigger for the declaration. A separate statutory threshold for the master and local file duty was not read from a primary source, so this page does not state one.
Use the declaration threshold as the anchor. The tax authority applies the TND 200 million test to turnover net of VAT at the Tunisian entity level, measured against the related-party transactions that entity runs with foreign group members.
What are Tunisia's master file and local file requirements?
Tunisia has not published a statutory content list for either file in the primary sources read, so the exact required fields are not confirmed. Tunisia is an Inclusive Framework member and its regime follows the three-tier design, so build both files to that template.
The master file describes the group: organisational structure, the business, intangibles, intercompany financing, and the consolidated financial and tax position. The local file covers the Tunisian entity's controlled transactions, its functional analysis, the selected method, comparables and benchmarking, and financial data that reconciles to the statutory accounts.
What Tunisia does state clearly is the production duty. You present the documentation when the tax authority issues a formal notice, and failing to produce it within 40 days triggers a penalty under the consolidated 2025 text of the Code of Tax Rights and Procedures[3]. So the local file is held and produced on request, never filed proactively.
Does Tunisia require country-by-country reporting?
Yes, for Tunisian ultimate parents only. A Tunisian parent of a multinational group with prior-year consolidated revenue excluding taxes of TND 1,636 million or more, roughly EUR 750 million, files a country-by-country report within 12 months of its fiscal year end. It goes in as an XML file through the tax authority's electronic portal, per the country-by-country filing guide published by the Ministry of Finance[4].
The obligation applies to fiscal years opened on or after 1 January 2020. The OECD 2025 peer review for Tunisia[5] confirms the threshold and the deadline, and records that local filing is suspended and surrogate parent filing is not permitted. A foreign-parented group therefore has nothing to file in Tunisia under this heading.
Does Tunisia have a country-by-country notification rule?
Not one that is confirmed. The peer review documents the filing threshold, the deadline and the suspended local filing, but no separate notification deadline or form is stated in the primary sources read. Treat notification as unconfirmed rather than assume a date from another jurisdiction.
What are Tunisia's transfer pricing deadlines?
Three dates, and only one of them is fixed in advance. The declaration follows the corporate income tax return. The country-by-country report is due 12 months after the fiscal year end. Documentation production runs on a 40-day clock that starts only when the tax authority asks.
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| Obligation | Deadline in 2026 | Source |
|---|---|---|
| Annual transfer pricing declaration | The same deadline as the annual corporate income tax return | Direction Generale des Impots, Tunisia |
| Country-by-country report | Within 12 months of the fiscal year end, as XML through the electronic portal | Direction Generale des Impots, Tunisia |
| Master and local file production | Within 40 days of a formal notice during an audit | Direction Generale des Impots, Tunisia |
The exact calendar date for the corporate income tax return depends on the entity's accounting close, so this page does not fix a day for it.
What are the penalties for transfer pricing non-compliance in Tunisia?
They split across the declaration, the documentation and the country-by-country report, and every amount below carries 2026 statutory force.
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| Breach | Penalty in 2026 | Source |
|---|---|---|
| Documentation not produced within 40 days of a notice | 0.5% of the transactions concerned, with a floor of TND 50,000 for each fiscal year under audit | Direction Generale des Impots, Tunisia |
| Annual declaration not filed | TND 10,000, plus TND 50 per defective item, capped at TND 5,000 | Direction Generale des Impots, Tunisia |
| Country-by-country report filed late | TND 50,000 fixed fine | Direction Generale des Impots, Tunisia |
| Country-by-country report incomplete or inaccurate | TND 100 per item, capped at TND 10,000 | Direction Generale des Impots, Tunisia |
The fines are not where the real money sits. When documentation is absent at audit, the burden of proof shifts to the taxpayer, and the tax authority can add understated profit back into the Tunisian entity's taxable base. That adjustment usually dwarfs every fixed fine on this page.
What language and currency apply to Tunisian transfer pricing documentation?
The tax authority publishes its declaration form and its country-by-country guide in French, and every threshold is set in Tunisian dinar. A statutory language rule for the master and local file, including whether English is accepted or a certified translation is required, is not confirmed in the primary sources read.
In practice, prepare the filings in French and hold the thresholds in dinar. North African comparables are thin, so most groups benchmark against regional or European data and reconcile the result to dinar inside the local file.
How does Tunisia compare with the OECD baseline?
Tunisia is not an OECD member, but it joined the Inclusive Framework in 2017, per the OECD Inclusive Framework composition list[6]. The regime follows the three-tier design by choice, while Tunisian statute, not OECD guidance, governs.
Two deltas matter for a foreign parent. Thresholds are set in dinar rather than euro, so an exchange rate move can pull an entity over the line without its business changing. And the forms are in French, which turns the 40-day production window into a translation problem as well as a documentation one.
How we help with Tunisia transfer pricing
Tunisia gives you 40 days from a notice to produce files whose statutory content list was never published. That is a hard brief to meet from a standing start. We build the master file and the local file to the three-tier template, run the benchmarking where North African comparables are thin, and track the TND 200 million declaration trigger and the TND 1,636 million reporting threshold against your actual numbers. See how our transfer pricing software works.
Book a demo to get a Tunisia documentation exposure check before your next corporate income tax return.
Official sources
6 sources
- 1.OECD. Transfer pricing country profile: Tunisia
- 2.Ministry of Finance, Tunisia. Annual transfer pricing declaration form
- 3.Jibaya tax portal, Tunisia. Code of Tax Rights and Procedures, consolidated 2025 text
- 4.Ministry of Finance, Tunisia. Country-by-country report filing guide
- 5.OECD. Country-by-country reporting, compilation of 2025 peer review reports: Tunisia
- 6.OECD. Inclusive Framework on BEPS composition list
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.
