Botswana Introduces New Transfer Pricing Regulations

Botswana's Income Tax (Transfer Pricing) Regulations, 2026 came into effect on 1 July 2026, introducing a more detailed framework for the pricing and documentation of transactions between associated parties. 

The Regulations apply primarily to international transactions but can also extend to certain domestic arrangements. These include transactions involving a foreign permanent establishment of one or more Botswana residents and arrangements where an associate benefits from a concessionary tax regime in Botswana. 

For businesses with cross-border related-party transactions, the new Regulations require closer attention to how pricing methods are selected, the comparables used to support them and the documentation maintained.