Corporate - Significant developments

Last reviewed - 24 July 2021

On 12 September 2017, the Mozambican Council of Ministers approved the Decree no. 70/2017 of 6 December that regulates the transfer pricing regime.

This regime contain rules with huge impact in the transactions between related entities, introduces some concepts, and lists the obligations related with information to be provided for transfer pricing purposes. Main topics include the following:

  • The concept of 'related parties' is introduced for the purpose of transfer pricing.
  • A number of methods are listed to determine the terms and conditions that would be established in compliance with the 'arm's-length principle'.
  • Specific rules are established to be observed in the agreements to be entered between related parties.
  • The list of information and documentation is established that the taxpayer should obtain, prepare, and maintain to justify the adopted transfer pricing method.