African and OECD TP updates: July 2026

A round-up of transfer pricing and related updates from around the African continent and beyond.

(Sources: reports issued by organisations, government documents and legislation (where available) or other tax news platforms, such as Orbitax, MNETax, etc.)

OECD consults on copper pricing framework

The OECD and IGF have launched a consultation on a transfer pricing framework for copper, applying the “Determining the Price of Minerals” approach to one of Africa’s most important mineral commodities. This is relevant for mining jurisdictions and MNEs involved in commodity supply chains. Source: OECD

OECD reviews guidance on intra-group services

The OECD has released a 2026 public consultation document proposing revisions to Chapter VII of the OECD Transfer Pricing Guidelines, focused on intra-group services. The draft aims to modernise and clarify the guidance without changing the underlying principles. Source: OECD

ATAF and OECD support Amount B capacity building in Africa

ATAF and the OECD completed joint workshops on transfer pricing simplification for African tax administrations, bringing together more than 130 participants from 17 African countries. The work forms part of broader support for the implementation of Amount B. Source: ATAF

South Africa opens Global Minimum Tax registration on eFiling

SARS launched Global Minimum Tax registration and notification functionality on eFiling from 16 March 2026, marking an important administrative step in South Africa’s implementation of the GloBE framework. Source: South African Revenue Service

Kenya introduces advance pricing agreements

Kenya has introduced a formal APA framework, effective from 1 January 2026, allowing taxpayers to agree transfer pricing methodologies in advance with the KRA. This is a significant development for tax certainty and dispute prevention in East Africa. Source: KRA

Tanzania expands TP penalties to loss-making entities

Tanzania’s Finance Act, 2025 expands the TP penalty regime to include loss-making entities, with a penalty equal to 30% of the adjusted loss. This is an important compliance risk for MNEs operating in Tanzania. Source: Tanzania Revenue Authority / Finance Act (PDF download)

DRC introduces CbC reporting and TP measures

The DRC’s Finance Law 2026 introduced CbC reporting obligations, transfer pricing measures and other tax changes. This signals continued movement towards greater transparency and reporting requirements in African jurisdictions. Source: DRC Ministry of Finance

Uganda TP dispute highlights audit risk

Uganda’s Tax Appeals Tribunal backed the URA in a UGX 10.2 billion dispute involving Century Bottling, with the ruling addressing issues including assessments based on new audit facts. This is another reminder of growing TP controversy risk on the continent. Source: CEO East Africa

Côte d’Ivoire introduces APAs

Under the 2026 Finance Law, Côte d’Ivoire has introduced APAs as part of its transfer pricing framework, giving taxpayers a route to greater certainty on agreed TP policies. Source: Direction Générale des Impôts (DGI)

Morocco approves TP documentation decree

Morocco’s Cabinet approved Draft Decree No. 2.22.1020, setting out transfer pricing documentation requirements and submission procedures. This continues the strengthening of TP compliance frameworks in Francophone Africa. Source: Bloomberg Tax