Ethiopia Transfer Pricing Directive

The Ethiopian Ministry of Finance (MoF) has issued directive no 981/2024 (The Directive) which contains new transfer pricing rules effective January 2024. This Directive repeals the Transfer Pricing Rules Directive No 43/2015.

The Directive has been issued in line with the transfer pricing provisions under Section 79 of the Federal Income Tax Proclamation No. 979/2016 (ITP), and is substantially aligned to the OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations. It provides detailed transfer pricing rules to guide the pricing of controlled transactions, in line with the provisions of Article 79 of the ITP which concerns the pricing of international and domestic transactions between related persons whose annual turnover exceeds Birr 500,000. 

Click and donwload the document below to read the key provisions covered under The Directive;