Mauritania Transfer Pricing and CbCR

General reference only. This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

2026 research draft, source baseline only. The computations below reproduce the cited official code/provisions, not a certified complete statement of operative 2026 law. The January 2023 official code lists amendments only through the January 2022 Finance Act. Selected later Finance Acts were read, including the 2024 transfer-pricing replacement, but the complete commencement/publication chain is not closed. The signed/stamped rectifying Finance Act is visibly numbered 2026-035 on physical page 6. It changes material expense, digital-service and compliance rules; the retained comparison-column headings do not establish proposal status, and its upload date does not prove the operative date. [N02] Resolve the amendment file before using these baselines to file, pay or advise. No accountant has signed this revision.

Who this applies to

Related business transactions involving Mauritania and prescribed large-entity reporting. Separate the substantive adjustment, annual art. 65 disclosure, art. 66 documentation and art. 67 CbCR tests. This Guide reads the material 2024 replacements rather than reproducing the older code’s foreign-only documentation scope and MRU 22 billion CbCR threshold.

Rates, bands and thresholds

Item	Rule and conditions	Official source
Annual TP disclosure [T02]	A Mauritanian legal person discloses annually if its tax-exclusive turnover or gross assets are at least MRU 30,000,000, or if it holds/is held by more than half the capital/votes of another entity meeting that test. Declaration under art. 65 is due with the art. 59 annual return. Do not treat it as the same obligation as keeping documentation or filing CbCR.	CGI art. 65
Documentation perimeter after 2024 [T04]	The replacement art. 66 requires eligible Mauritanian legal persons to support transactions with associated enterprises in Mauritania or abroad. Eligibility uses own turnover/gross assets of at least MRU 30,000,000, or majority capital/vote ownership links to an entity meeting that test. This broadens the older foreign-transactions-only wording.	LFI2024 art. 3.1 replacing CGI art. 66(1)–(2), physical pp. 7–8
CbCR ultimate-parent test after 2024 [T06]	Replacement art. 67 requires electronic CbCR within twelve months after year-end for a Mauritanian ultimate parent satisfying consolidation/control tests and prior-year tax-exclusive consolidated turnover of at least MRU 25,000,000,000. The old MRU 22 billion number in the 2023 code is superseded. Do not substitute a EUR 750 million threshold.	LFI2024 replacement CGI art. 67(1), physical pp. 8–9

The base

• Arm’s length adjustment [T01]. CGI art. 40 compares connected businesses with independent conditions and adds indirectly shifted profits back. It covers links within Mauritania and abroad, with majority ownership, de facto decision power or common control. For privileged-tax-jurisdiction dealings under art. 23, a control link is not required. CGI arts. 23, 40.
• Disclosure content [T03]. The annual TP declaration describes group activity/policy/intangibles, the local activity, related transactions by amount/nature/counterparty/jurisdiction/method, related loans, no-cash/no-consideration dealings and foreign APAs/rulings on those transactions. Use the prescribed DGI format. CGI art. 65(2).
• CbCR local filing and substitution [T07]. Replacement art. 67(2)–(5) adds local filing for specified foreign-parent nonfiling/nonexchange/systemic-failure situations. A non-ultimate local entity escapes via substitute filing only if all six listed conditions hold: similar filing law, automatic exchange agreement in force by due date, no notified systemic failure, actual exchange, reporting entity designation notified abroad, and local DGI notification of reporting identity/jurisdiction. Multiple eligible local entities can designate one with DGI notification. LFI2024 replacement CGI art. 67(2)–(5), physical pp. 9–11.

Deadlines and filing

• Documentation readiness and cure [T05]. Keep general group and specific local documentation, with content fixed by ministerial order, available when the on-site audit begins; it does not replace transaction evidence. If absent/partial, the written formal notice identifies missing items and gives 15 days to supply/complete. The revised text contains duplicated words and an inconsistent penalty cross-reference; use L.131(6) itself for the amount, not the art. 66 reference alone. LFI2024 replacement CGI art. 66(3)–(5), physical pp. 7–8.

Penalties and interest

• TP and CbCR penalties [T08]. As amended in 2024, L.131(5) charges MRU 2,500,000 for late/missing, incomplete or inaccurate annual TP declarations. L.131(6) charges 0.5% of affected transactions per audited year after unanswered/incomplete formal notice, minimum MRU 500,000. L.131(7) charges MRU 4,000,000 for late/missing, incomplete or inaccurate CbCR. Do not add these automatically to an arm’s-length profit adjustment without identifying each breach. LFI2024 replacement LPF L.131(5)–(7), physical pp. 14–15.

Cross-border points

Domestic connected transactions are within the replacement documentation scope; cross-border links are not the only trigger. The privileged-tax-jurisdiction rule can apply without a control link. Treaty relief, actual exchange arrangements, the jurisdiction list and a substitution notification must be established for the reporting period.

Two worked examples that recompute

1. Majority-linked documentation test

Assume the replacement art. 66 applies: a Mauritanian subsidiary has turnover MRU 12m and assets 20m but a parent owns 60% and has turnover 40m. The subsidiary falls within the majority-linked documentation test although its own figures are below 30m. The excess parent turnover over threshold is 10m; a 50% holding would not satisfy the more-than-half ownership limb, absent another control/eligibility fact.

name: Majority-linked documentation test
inputs:
  parent_turnover: 40000000
  local_turnover: 12000000
  local_assets: 20000000
  ownership: 60
steps:
  - parent_excess: parent_turnover - 30000000
  - local_gap: 30000000 - max(local_turnover, local_assets)
  - ownership_excess: ownership - 50
expected:
  parent_excess: 10000000
  local_gap: 10000000
  ownership_excess: 10

2. Documentation penalty: percentage or minimum

Assume the revised L.131(6) conditions are satisfied after an unanswered/incomplete formal notice, for one audited year. Missing supporting transactions of MRU 20m give 100,000 at 0.5%, so choose the 500,000 minimum. For affected transactions of 200m choose 1m, above that minimum. These are documentary penalties, not the tax on an arm’s-length adjustment.

name: Documentation penalty: percentage or minimum
inputs:
  small_transactions: 20000000
  large_transactions: 200000000
steps:
  - small_penalty: max(small_transactions * 0.005, 500000)
  - large_penalty: max(large_transactions * 0.005, 500000)
expected:
  small_penalty: 500000
  large_penalty: 1000000

Ask the client first

• Ownership/vote chart and de facto decision power at year-end?
• Own and linked-entity turnover/gross assets, and prior-year consolidated turnover?
• All related transactions, jurisdictions, loans, intangibles, APAs and noncash dealings?
• Consolidation/ultimate-parent status and reporting entity location?
• Local audit start/formal notice dates, supplied evidence and reporting notifications?

Sources

Source and exact scope read	URL	Read on
cgi2023: Official version cover/amendment list and selected CGI arts. 1–14, 23–24, 40–48, 49–67, 68–98, 99–118, 119–137, 150–157, 209–215 (exemption list introductory categories only), 216–221, 227–250, 253–254, LPF L.131–L.139. Not the entire 168-page code or full sector/special regimes.	https://finances.gov.mr/sites/default/files/2023-03/CGI-Fr-2023.pdf	2026-11-01
lfi2024: OCR physical pp. 6–21; tax amendment provisions, especially replacement arts. 66–67, 120/125 and LPF L.3/L.25/L.131. Physical p. 8 visually inspected for duplicated wording. Not budget appropriations or full annexes.	https://www.finances.gov.mr/sites/default/files/2024-01/LFI%20%202024%20FR%20.pdf	2026-11-01
Amendment hold: signed/stamped law 2026-035 identity on physical page 6 and art. 3.1 printed pp. 6–18 read; operative date not established	https://www.finances.gov.mr/sites/default/files/2026-08/LFR%202026%20FR.pdf	2026-11-01

Not yet confirmed: complete operative 2026 amendment chain, ministerial documentation-content order and current DGI art. 65 submission form; CbCR implementing order 00204 captured but not yet read, reporting schema/portal and current exchange/jurisdiction list; treaty mutual-agreement/corresponding adjustment procedure and any accepted pricing-method hierarchy; 2024 art. 66 duplicated wording/inconsistent reference to L.131(5), while L.131(6) specifies the documentary-notice penalty.