Companies, etc. are taxable on a stand-alone basis (i.e. there is no grouping or ability to transfer tax losses).
Excessive payments or compensation to ‘members of a legal person’ or payments between associates for work performed should not be deductible. The TDA, however, does not provide specific guidance on how to determine arm’s-length pricing on related-party transactions or any other general transfer pricing principles.
Currently, there are no ‘thin capitalisation’ or similar rules in Timor-Leste (noting that interest is not deductible, except for financial institutions).
Controlled foreign companies (CFCs)
Timor-Leste does not have any CFC regulations.