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Zimbabwe: Transfer pricing annual return, documentation measures in 2019 budget

Zimbabwe: Transfer pricing annual return, 2019 budget

Zimbabwe’s budget for 2019 was presented on 22 November 2018, and includes transfer pricing proposals. The transfer pricing measures would be effective from 1 January 2019.


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Among the transfer pricing measures proposed in the 2019 budget are the following:

  • A requirement to file an annual transfer pricing return 
  • Authority for the tax administration (ZIMRA) to provide guidelines for transfer pricing documentation 
  • Penalties for non-compliance with the transfer pricing requirements in amounts equal to:
    • 10% of the “shortfall” tax liability when the taxpayer was in compliance with 35th schedule and contemporaneous transfer pricing documentation
    • 30% of the shortfall tax liability on non-compliance with 35th schedule or non-existence of contemporaneous transfer pricing documentation
    • 100% of the shortfall tax liability on tax evasion and deliberate postponement of tax liability when there was no transfer pricing documentation 


Read a November 2018 report [PDF 1.6 MB] prepared by the KPMG member firm in Zimbabwe

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