East Africa Transfer Pricing Guidelines - 2022

On 20 January 2022, the OECD released the revised Transfer Pricing Guidelines.

Prior to this release, the 2017 guidelines that had included significant changes following the OECD’s work on Base Erosion and Profit Shifting (BEPS). While the 2022 revised edition also follows the OECD’s work on BEPS, its main changes constitute the consolidation of changes to the 2017 edition resulting from guidance reports issued by the OECD since then.

The main changes include:

• Revised Guidance on the Transactional Profit Split Method
• Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles
• Transfer Pricing Guidance on Financial Transactions

The consistency changes to the rest of the OECD Transfer Pricing Guidelines needed to produce this consolidated version of the Transfer Pricing Guidelines.

These changes are relevant to East Africa as much as they are to the world. In this publication, we summarise these changes and how they impact the respective countries in East Africa.