International tax · Transfer pricing
Since financial years opened in 2020, every Tunisian company transacting with related parties must be able to show that its intragroup prices are at arm's length, file an annual transfer pricing return above a turnover threshold and keep documentation above a second threshold. MGI BFC supports foreign-owned subsidiaries and Tunisian groups: diagnosis of flows, transfer pricing policy, return, documentation, defence in case of audit.
Inventory of transactions with related parties, identification of risks (management fees without substance, interest-free loans, undocumented royalties), quantification of exposures and action plan.
Choice of method (comparable uncontrolled price, resale price, cost plus, transactional net margin, profit split), drafting or review of intragroup agreements, consistency between the group policy, the accounts and the returns.
Preparation and filing of the annual return for related companies whose turnover reaches TND 20 million, together with the corporate tax return; consistency checks with the financial statements and withholding taxes.
OECD-standard documentation (master file and local file), mandatory from TND 200 million of turnover and recommended below as soon as flows are significant; benchmarking studies and functional analysis.
Preparation before the audit, assistance during the procedure, written answers to the administration, negotiation, appeals; coordination with your legal advisers and with head office.
Withholding taxes on services, royalties, interest and dividends, application of tax treaties, VAT on imported services, exchange-control rules on payments to the group; together with our tax advisory service.
1. Diagnosis. Review of flows, agreements and existing returns; identification of gaps and priorities; written scope.
2. Design. Transfer pricing policy, method per flow, agreements, position paper; validation with head office and your advisers.
3. Implementation. Annual return, documentation, accounting adjustments if needed, withholding tax set-up.
4. Follow-up and defence. Annual update, monitoring of finance laws, assistance in case of audit.
Office: Golden Tower Building B8.2, Centre Urbain Nord, 1082 Tunis. We work throughout Tunisia and remotely.
From TND 20 million of annual gross turnover, for companies with related-party transactions; it is filed with the corporate tax return. Failure to file is sanctioned by a TND 10,000 fine.
Related companies whose turnover reaches TND 200 million; the documentation is presented to the administration at the start of a tax audit. Below that threshold, lighter documentation remains strongly recommended: it is what justifies your prices in an audit.
Yes, when they correspond to services actually rendered, useful to the Tunisian company, priced at arm's length and documented (agreement, evidence, allocation key); withholding taxes and VAT on imported services must also be handled. An undocumented lump sum is the first adjustment requested in an audit.
Beyond fines (TND 50 per missing item, capped at TND 5,000), the main risk is the reintegration of profits deemed transferred and the related penalties, as well as the challenge of withholding taxes applied. Documentation prepared in advance is the best defence.
Send us the list of your intragroup flows and your latest financial statements through our request-for-proposal form; a partner answers within 24 hours with a first-level diagnosis.
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