Mauritania

Transfer pricing regime

To establish the payable CIT by companies that are dependent upon or control companies located in Mauritania or outside Mauritania, profits indirectly transferred to the latter, whether by increasing or decreasing the purchase or selling prices or by any other means, shall be included in the profit shown in the accounting. The profits indirectly transferred shall be determined by comparison with the profits that would have been realised in an arm's-length or controlling relationship.

The condition of dependence or control laid down shall not be required where the transfer is made with undertakings established in a foreign state or outside Mauritania that enjoy preferential tax treatment within the meaning of Article 23.

Ties of dependence or control shall be deemed to exist between two undertakings:

1. when one holds directly or through an intermediary the majority of the share capital of the other or actually exercises the power of decision thereat, or
2. when they are both, under the conditions set out in (a), under the control of the same undertaking or person.

Persons who are in such relationships are required to maintain all documentation that justify the pricing policy being applied .

Thin capitalisation 

Mauritania’s thin capitalisation rules limit interest deductions for corporate tax. Generally, the cap on interest allowable is at the central bank rate plus two percentage points.
Net deductible interest is capped at 25% of taxable profit plus interest, depreciation and provisions (an EBITDA type measure), subject to some variations for group entities.

Disallowed interest can be carried forward for up to three years, with some exceptions.