The tax administration has recently issued common notes related to transfer pricing (of goods, services, or materials) used between group companies and applicable to companies with an annual turnover exceeding 20 million TND.

Three common notes have been published :

• Common Note No. 13 : contains the template for the tax declaration,
• Common Note No. 12 : outlines the advance agreement process with the tax administration regarding transfer pricing,
• Common Note No. 11 : aligns tunisian legislation with international standards on transfer pricing.

It is important to note that all companies with a turnover exceeding 20 million TND (managed by the Large Taxpayer Unit) are now required to file annual transfer pricing declarations.

The penalties for non-compliance include a fine of 0.5% of the transaction amount related to documents not submitted, incomplete, or inaccurate, with a minimum fine of 50,000 TND per fiscal year. Thus, even in cases of incomplete or incorrect information, the tax administration may impose the minimum penalty of 50,000 TND.