Transfer Pricing

Transfer pricing refers to the setting, analysis, documentation and adjustment of cross border charges between related parties for goods, services, or use of property (including intangible property).

It should be noted that Transfer Pricing is a highly specialised field of taxation.

This information shared aims to provide a brief overview of the situation in Namibia, it should not be considered as a complete guide to Transfer Pricing.

Transfer pricing legislation is essentially aimed at ensuring that cross-border transactions between companies operating in a multinational group are fairly prices and that profits are not stripped from Namibia and taxed in lower tax jurisdictions.

International Transactions

An "international transaction" is a transaction for the supply of goods entered into between:

• a resident person and a non-resident person;
• two non-resident persons, onw of whom supplies goods or services to a permanent establishment of the other in Namibia;
• two resident persons, one of whom supplies goods or services to a permanent establishment of the other outside Namibia;
• two resident persons, one of whom is not subject to tax in Namibia because of a double taxation agreement.