Senegal: Transfer pricing - Overview of documentation and reporting requirements in Senegal

Recent tax developments from different countries on the continent africa.

In an international context marked by the fight against tax fraud and evasion, notably through Action 13 of the OECD's BEPS plan, many countries have strengthened their transfer pricing requirements.

In this article, we explore the special depreciation regimes in the extractive sector of Senegal. 

Recent tax developments from nine countries on the continent.

Senegal, in 2024, is a leading African investment hub, fueled by growth in energy, infrastructure, and agriculture. With political stability, modern infrastructure, and investor-friendly reforms, it provides access to ECOWAS and AFCFTA markets, offering tax incentives for sustainable investments.

Recent tax developments on the continent.

Adopted in line with the forecasts set out in the Initial Finance Act (PLFI), the Finance Act for 2025 introduces several major tax reforms aimed at modernizing tax administration and enhancing transparency.

Recent tax developments from nine countries on the continent.

Senegal is modernizing its VAT framework for digital services, aligning with global standards. This article outlines the key features of the VAT regime on digital services.

Recent tax developments from nine countries on the continent.

The Initial Finance Act (LFI) for 2024 implemented substantial modifications to the Senegalese General Tax Code (GTC) aimed at modernizing and harmonizing the tax framework.

Recent tax developments from eight countries on the continent.

Senegal has adopted the new Environmental Code in 2023, which replaces the 2001 version, to address challenges arising from increased production activities, demographic pressures, and natural resource extraction.

In African economies, extractive industries are key, heavily regulated by authorities to maximize tax revenue, underscoring the importance of a clear "Permanent Establishment" (PE) concept, particularly in Senegal's expanding sector.

Recent tax developments from eight countries on the continent.

Transfer pricing in Senegal has taken a significant step forward in terms of aligning with international taxation norms, marked by the Minister of Finance's order on 1 August 2023, detailing transfer pricing documentation content.

Senegalese tax legislation references the arm's length principle since the 2018 Finance Act, particularly in Article 17, paragraph 1 of the General Tax Code, and provides for related party notion.

For the benefit of the tax deductibility of credit losses enshrined in the IFL 2023, banking and financial institutions are required to meet certain substantive and formal requirements.

Ensuring greater social justice in the distribution of the tax burden" is one of the objectives pursued by the Amending Finance Law (LFR) for the year 2022.

More than 5 years after the signature of the Multilateral Instrument (MLI) on June 7, 2017, Senegal deposited its instrument of ratification of the Multilateral Convention on May 10, 2022.

According to Decree No. 2021-928 of 8 July 2021, which established PROMAD, the basis for this levy is the customs value of eligible goods.

In Senegal, the Transfer Pricing provisions, largely inspired by the OECD Guidelines 2017, have been incorporated into the Senegalese General Tax Code.

Senegal is currently implementing several BEPS action items into local tax laws. Our colleagues explain which actions have been implemented and how these changes will affect companies.

Within the framework of the OECD Convention on Mutual Administrative Assistance relating to Taxation, Senegal has signed the Multilateral Convention called MLI.

An insight on the new regulations of the Senegalese tax law on transfer pricing.

Article published in ITP Newsletter #1/2019

Overview of the major changes