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13.4.3. Documentation Requirements

Standard Documentation

Taxpayers are required to maintain contemporaneous transfer pricing documentation in relation to their transactions with related parties. From the year ending 31 December 2020, all taxpayers engaged in cross-border transactions with related parties, regardless of the amount, are required to submit a Master file and a Local file.

The Transfer pricing documentation should provide the following information:

  • The nature of the relationship between the company and other companies or group companies based in or outside Madagascar;
  • The TP method used in determining the value of the transaction entered with associated enterprises, supported by comparable, if applicable;
  • The nature of transactions entered into with the associated enterprises;
  • The tax treatment of the transactions carried out by non-resident companies or groups that directly or indirectly holds a majority of the capital or voting rights in the company.

The tax authorities may require the taxpayer to submit Transfer pricing documentation during a tax audit. The documentation is required to be provided to the tax authorities within 2 months (extendable to 3 months) on request.

Master File

The contents of the Master file include:

  • Details of MNE’s group structure; and
  • General information.

Local File

The contents of the Local file include:

  • Details of the local entity;
  • Details of controlled transactions; and
  • Financial information of the local entity;

The documentation can be submitted electronically or in hard copy by:

  • 15 May for years ending 31 December;
  • 15 November for years ending 30 June; and
  • the 15th day of the fourth month following other year-ends.

For the year ending on 31 December 2020, the deadline is extended to 31 October 2021. The documentation is required to be maintained for a period of 10 years.

Country-by-Country Reporting

Madagascar has till date not introduced a Country-by-Country reporting requirement and has not yet joined the OECDs Inclusive Framework, membership of which presupposes a commitment to implement the BEPS minimum standards, including Country-by-Country reporting.

Language of Documentation

The Master file and Local file are required to be submitted in the French language.


Failure to provide documentation or insufficient documentation within the time limit provided by the tax authorities attracts a penalty of MGA 5 million.