Botswana's new Income Tax (Transfer Pricing) Regulations, 2026 establish a comprehensive framework for pricing and documenting related-party transactions. The regulations introduce a hierarchical approach to transfer pricing methods, specific requirements for comparables selection, and strict contemporaneous documentation obligations that fundamentally change how multinational businesses must approach their cross-border arrangements.

Botswana, formerly a British protectorate, became independent in 1966. It is a landlocked country in southern Africa, bordered by Zimbabwe to the northeast, South Africa to the south-east, and Namibia to the west.