Liberia, Republic of

Transfer pricing regime

Liberia’s Transfer Pricing (TP) Regulations provide that all related parties' transactions are required to be reported by filing a TP return. The TP return is to be filed along with the CIT return on the last day of the third month following the end of the tax year. For a taxpayer using the calendar year, it is due 31 March.

The arm's-length remuneration of a transaction is to be determined by using any of the below appropriate TP methods, which are the acceptable methods by the authorities:

• The comparable uncontrolled method.
• The cost-plus method.
• The resale price method.
• The transaction net margin method.
• The transactional profit split method.
• Any other method that is approved in writing by the Commissioner General of the LRA.

The TP Regulations also require that the master and local files are prepared and presented to the LRA upon request.

Thin capitalisation rules

There are no thin capitalisation rules in Liberia. See Interest expenses in the Deductions section for the rule for interest deductibility.

Controlled foreign companies (CFCs)

There are no CFC rules in Liberia.