The dormant 2015 Transfer Pricing
("TP") Directive was recently renumbered
and reissued by the Ethiopian Ministry of Finance as
"Directive to Provide Rules on Transfer Pricing
Directive No. 981/2024." The reissued Directive deals
with procedural requirements of laws issued after the 2015 TP
Directive.
The Ministry of Finance has announced in 2023 that it would
start implementing the TP rules from the beginning of this tax
year, and this renaming is a clear signal that the Government is
serious about the implementation of TP rules and regulations.
The renumbered Directive does not apply retrospectively but
would become effective from the date of its registration by the
Ministry of Justice and uploading on the website of the Ministry of
Finance.
