Eswatini

Transfer Pricing in Eswatini

Eswatini transfer pricing for the year of assessment 1 July 2025 to 30 June 2026 (tax year 2026) under sections 65quat, 65quin and 65sex of the Income Tax Order 1975, added by the Income Tax (Amendment) Act 2023 (Act 20 of 2023) and in force from 1 July 2024. Covers who is an associate person (relatives, partners, trusts, 50% control, acting on directions), controlled transactions, permanent establishments and head office charges, the arm's length rule, the five approved methods and the most-appropriate-method test, the tested party, OECD Guidelines as interpretation aid, the commodity quoted-price rule, beneficial tax regime counterparties, the intangibles cap, documentation and record keeping, additional tax, interest and offences.