Seychelles has introduced new transfer pricing documentation and related party dealings schedule requirements with effect from 1 January 2024, as well as certain other measures. Transfer Pricing Documentation A person with annual turnover exceeding SCR 1,000,000 that enters into controlled arrangements must prepare documentation verifying that the conditions in its controlled arrangements for the relevant tax year are consistent with the arm's length principle. A controlled arrangement for this purpose means: An arrangement between associates, including an arrangement attributed to a permanent establishment of one or both of the associates; and An arrangement between a person and a permanent establishment...