Many African countries have reported that transfer pricing is one of the most significant risks to their tax base. Almost all such countries report that they use the global standard of the arm’s length principle to address transfer pricing risk and broadly follow the guidance set out in the OECD Transfer Pricing Guidelines.

However, as with a lot of developing countries, many MNCs operating in Africa report that they tend to get allocated routine returns with the real economic reward being allocated abroad – so work clearly needs to be done and working in a TP career in Africa at the present time provides huge challenges that can also be hugely rewarding.