Namibia: Transfer pricing adjustments when transaction not at arm’s length

Namibia’s transfer pricing provisions

Namibia’s transfer pricing provisions

Under Namibia’s transfer pricing provisions, to determine the taxable income of an acquirer or supplier in an international transaction when connected persons are involved, the Minister of Finance may adjust the consideration to reflect an arm’s length price when the goods or services are supplied or acquired at a price less than or greater than the arm’s length price.

The Minister of Finance has the authority to adjust the liability of a taxpayer when it is considered that such a transaction, scheme or operation has the effect of avoiding or postponing liability for the payment of any tax imposed under the income tax law if the transaction was entered into in a certain manner or gives rise to rights not normally created in arm’s length transactions.

Read a September 2021 report prepared by the KPMG member firm in Namibia


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