Comoros: transfer pricing

Who this applies to

Companies in Comoros that control, or are controlled by, a company in or outside Comoros. Control means holding more than 50% of capital or votes, directly or through another person, or in fact holding the decision-making power. Two companies under the same controller also count (CGI art. 31(2)). No control link is needed for transfers to a business in a state with a privileged tax regime (art. 31(3)).

Rates, bands and thresholds

Item	Figure	Year	Source
Control test	More than 50% of capital or votes, or de facto control (art. 31(2))	2026	https://finances.gouv.km/wp-content/uploads/2024/12/LOI-DE-FINANCES-RECTIFICATIVES-2024.pdf
Privileged tax regime	Not taxable there, or profit tax at least 40% lower than Comoros tax (art. 31 bis)	2026	same
Declaration and documentation threshold	Turnover excluding tax or gross assets of KMF 80,000,000 or more, in the company, a held company or a holder (art. 43 bis, L.21 bis)	2026	same
Fine for no, incomplete or inaccurate declaration	KMF 50,000,000 fixed (L.101 bis)	2026	same
Fine after a documentation notice	2% of the transactions concerned, at least KMF 25,000,000 per audited year (L.114 bis)	2026	same

The base

Profits moved indirectly, by raising or lowering prices or any other means, are added back to the company's results. The amount is measured against what would have been earned with no link (art. 31(1)).

Deadlines and filing

• Annual declaration: same deadline as the profit return, 30 April under the 2023 code art. 42(1) ("au plus tard le 30 avril"), on the tax authority's form (art. 43 bis). It covers group information and the company's own related-party transactions, loans, non-cash transactions and advance agreements or rulings with other states.
• Documentation: available on the date an audit starts (L.21 bis). It does not replace evidence for each transaction. Its content is set by order of the Finance Minister.
• Companies below the threshold: on audit, 15 days to answer an L.21 request, then 8 days after a formal notice.
• Companies above the threshold: 8 days after a formal notice (L.21 bis(5)).

Penalties and interest

L.101 bis applies to the declaration. L.114 bis applies, per audited year, to failure after an L.21 bis notice, and art. L.21 applies the same fine to failure after an L.21 notice.

Cross-border points

The rule covers links in and outside Comoros, so domestic groups are included. A foreign information request under a treaty can extend on-site audit time by three months (L.42).

Two worked examples that recompute

A company receives a notice and leaves transactions of KMF 900,000,000 undocumented. 2% is KMF 18,000,000, below the floor, so the fine is KMF 25,000,000.

name: Fine at the floor
inputs:
  transactions: 900000000
steps:
  - fine: max(transactions * 0.02, 25000000)
expected:
  fine: 25000000

The same failure on KMF 2,000,000,000 gives 2%, KMF 40,000,000, above the floor.

name: Fine above the floor
inputs:
  transactions: 2000000000
steps:
  - fine: max(transactions * 0.02, 25000000)
expected:
  fine: 40000000

Ask the client first

• Who holds more than 50% of the company, and what does it hold?
• What are turnover and gross assets for each linked company?
• Are there payments to low-tax states, with or without a control link?

Sources

Source	URL	Read on
Law 24-013/AU of 27 August 2024, Amending Finance Law 2024, art. 10, pages 9 to 14, scan, OCR read	https://finances.gouv.km/wp-content/uploads/2024/12/LOI-DE-FINANCES-RECTIFICATIVES-2024.pdf	2026-11-01
Law 25-020/AU, Finance Law 2026, tax section; no change to these articles	https://finances.gouv.km/wp-content/uploads/2026/02/Decret-portant-promulgation-du-loi-des-finances-2026.pdf	2026-11-01
Code general des impots, 2023 edition, art. 42	https://justice.gouv.km/wp-content/uploads/2025/03/comores-cgi-2023.pdf	2026-11-01

Not yet confirmed: the Finance Minister's order on documentation content; the current declaration form; the Amending Finance Law 2025 (official link returned 404).