The Transfer Pricing Regime (TPR) published by Decree No.
70/2017, of 6 December, which entered into force on 1 January of
this year, established a set of rules that will govern
relationships between related parties.
The TPR applies to individuals and companies resident or
domiciled in Mozambique, and to permanent establishments of
companies non-resident in Mozambique that conduct transactions
associated with non-resident companies, as well as with other
permanent establishments of the same company situated outside
Mozambique.
In reality, the TPR develops and establishes the transfer
pricing rules provided for in the Corporate Income Tax Code (CIT
Code). Article 49 of the CIT Code had already established some
rules in respect of transfer prices, including the possibility for
the tax authorities to make any corrections necessary to determine
the taxable profit whenever, by virtue of special relationships
between the taxpayer and another person, whether or not
