Lesotho

Transfer Pricing in Lesotho

Lesotho transfer pricing for the 2026-27 year of assessment (1 April 2026 to 31 March 2027) under section 113 of the Income Tax Act 1993 as amended. Covers who is an associate (the directions or wishes test in section 3), the Commissioner General's power to distribute, apportion or allocate gross income, deductions and credits between associates, the commensurate-with-income rule for intangibles, recharacterisation of source and of revenue or capital, market value on non-arm's length disposals (s.61), disguised distributions taxed as dividends (s.88), the four-year window for amended assessments, records and additional tax, and Article 9 of the South Africa treaty. Lesotho has no transfer pricing regulations, documentation rule or advance pricing agreement in the law read.