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Ethiopia Updates Transfer Pricing Directive

29 March 2024

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Approved Changes

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Ethiopia

Ethiopia's Ministry of Finance has published Directive No. 981/2024, a Directive to Provide Rules on Transfer Pricing. Directive No. 981/2024 updates and replaces Directive No. 231/2021. The Directive concerns the pricing of international and domestic transactions between related persons whose annual turnover exceeds ETB 500,000, and covers: The application of the arm's length principle, including that where a taxpayer engages in a transaction with a related person, the taxpayer shall determine the amount of its taxable income in a manner that is consistent with the arm`s length principle; Rules on comparability, including that an uncontrolled transaction is comparable to a...