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May 15, 2026

Cabinet Decision No. 39 of 2019, Article 52, introduces formal transfer pricing requirements. Entities linked to others must consider these requirements when pricing transactions and reporting income. It adopts the definition of 'linked entities' from international accounting standards. Transfer prices refer to the value assigned to assets (physical or non-physical) and services transferred between these related parties. This ensures that cross-border and domestic inter-company transactions are reported transparently and reflect actual economic values, preventing the artificial shifting of profits to lower-tax jurisdictions.

SECTION 8 - TAX AVOIDANCE

Chapter 2 - Indirect Transfer of Profits between Related Entities

Article 52

Each entity linked to other entities must properly consider transfer pricing requirements when determining prices and other terms for transactions between them, and report the income from these transactions in their tax returns.

In this case, linked entities will bear definition set by international accounting standards.

Transfer prices, on the other hand, will refer to prices at which one entity transfers physical or non-physical assets or provides services to linked entities.