Tunisia has published a Ministerial Order setting out the country's new transfer pricing documentation requirements, which apply from 2020, as well as an Order on Country-by-Country (CbC) reporting. The Orders, which are dated 16 October 2019, were published in Tunisia's Official Gazette No. 086 of 25 October 2019.
The required documentation includes both a Master file and a Local file that follows OECD guidelines. The specific content requirements as set out in the Order are as follows:
The Master File should include information on the following:
The Local File should include information on the following:
The Ministerial Order on Tunisia's Country-by-Country (CbC) reporting requirements includes the relevant definitions and basic instructions in line with OECD guidelines, as well as a general form for submitting the CbC report. The form follows the standard three CbC report tables and may be prepared in French or English.
Tunisia's CbC reporting requirements apply for financial years beginning on or after 1 January 2020 for MNE groups with consolidated annual revenue equal to or exceeding TND 1,636,000,000 in the previous year. When required, CbC reports are due within 12 months after the end of the reporting financial year.
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