The Cabinet Secretary for the National Treasury has issued the Income Tax (Transfer Pricing) Rules, 2026 under Legal Notice No. 186 of 2026. Promulgated pursuant to Section 18(8) as read with Section 130 of the Income Tax Act, these new rules officially revoke and replace the legacy 2006 Transfer Pricing Rules (Legal Notice No. 67 of 2006).
While draft rules were subjected to public participation in September 2023, the final enacted version introduces strategic modifications—most notably concerning commodity transactions, where publicly quoted prices must now be benchmarked against a 30-day average window (15 days prior to and 15 days post the date of shipment).
As regulatory enforcement shifts toward greater transparency and robust audit scrutiny, taxpayers must proactively review intercompany agreements, functional analyses, and contemporaneous documentation frameworks.
Next Steps & Advisory Guidance:
Click on the link below for Our summary and comments on the key provisions of the 2026 Transfer Pricing Rules to understand how these regulatory updates impact your operations and tax exposure.
