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Transfer Pricing Rules In Seychelles Explained


As stated in Section 2 (g) of the Business Tax (Amendment) Act, 2022 “Transfer pricing” is defined as the determination of prices charged in transactions between associates.

Furthermore, Business Tax Act describes two persons as associates if the relationship between them is such that one may reasonably be expected to act in accordance with the intentions of the other, or both persons may reasonably be expected to act in accordance with the intentions of a third person.

Note that associate is not just about ownership, they are relationships and activities in conducting business, commercial and financial relations.


Where an arrangement exists between associates, different businesses of a person, businesses and other activities of a person, a person and a permanent establishment of that person, a person may not benefit from transfer pricing in Seychelles under actual circumstances that are at arm’s length or that are not in accordance with the arm’s length principle. (Section 54 of Business Tax (Amendment) Act, 2022).

The arm’s length principle refers to the idea that transactions between associates must be the same as to those formed through a similar transaction between parties who are not associates.

A person shall not conduct Commercial or financial relations” with another person that will result them in getting a transfer price benefit. Transfer pricing benefit means a benefit accruing to a person as a result of a difference between the actual conditions and the arm’s length conditions.


A person is considered to have obtained transfer pricing benefit if the actual conditions are different from the arm’s length conditions the actual circumstances led to one or more of the following outcomes. If the arm’s-length criteria had been in place:

– the person’s taxable income for a tax year would have been greater;
– the amount of the person’s loss for a tax year would have been less;
– the amount of the person’s tax concessions for a tax year would have been less;
– the amount of withholding tax that the person would have had to pay in relation to interest or royalties would have been higher.

When conducting a transfer pricing audit, the Commissioner General shall determine the transfer pricing benefit by calculating the difference in the actual and arm’s length amounts in;

– the taxable income of the person for a tax year
– the tax loss of the person for a tax year

This short post is not intended as an exhaustive explanation of the law. If you require detailed information about Transfer Pricing please contact the Seychelles Revenue Commission at:

Seychelles Revenue Commission Maison Collet, 3rd Floor
PO Box 50 Victoria, Mahe
Phone: 4293737
E-mail: commissioner@src.gov.sc
Web: www.src.gov.sc

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