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13.4.3. Documentation Requirements

Standard Documentation

The TP documentation is required to be provided to the tax authorities within 30 days of the request made by them.

There are no specific requirements for the type of TP documentation to be prepared by the taxpayer. However, it is in the taxpayer's interest to maintain proper records and documents that would demonstrate and justify the TP policies and procedures adopted for determining the arm's length price for related party transactions.

Language of Documentation

The TP documentation is required to be maintained in the English language.

Penalties

There are no specific penalties related to transfer pricing. However, general penalties applicable under the tax laws are applicable to TP cases (See Sec 14.5).

Country-by-Country (CbC) Reporting

Namibia till date has not introduced a Country-by-Country reporting requirement. However, it has joined the OECD's Inclusive Framework, membership of which presupposes a commitment to implement the BEPS minimum standards, including Country-by-Country reporting.