Taxpayers engaged in international transactions with related parties, where the transaction value in a tax year exceeds ETB 500,000, are required to prepare a ‘transfer pricing declaration’ form to disclose such transactions.
Detailed TP documentation, in respect of domestic and cross border transactions, is required to be maintained by the taxpayers.
Taxpayers are required to prepare the TP documentation by the due date of filing of tax return. Documentation is required to be submitted within 45 days from the date of receipt of written request by the tax authorities.
The documentation can be prepared in Amharic or English language.
Ethiopia has till date not introduced a Country-by-Country reporting requirement and has not yet joined the OECD’s Inclusive Framework which presupposes a commitment to implement the BEPS minimum standards, including Country-by-Country reporting.