Td Transfer Pricing

---
name: td-transfer-pricing
description: "Prepare Chad transfer pricing working papers for 2026 for foreign related-party dealings and indirect profit transfers. Covers control and transaction mapping, functions, assets and risks, selection and explanation of an arm’s-length method, purchase and sale profit adjustments, the turnover-or-assets documentation threshold, general group and entity-specific support, DSF attachment and information-request periods. Use for Chad related-party services, intercompany purchases, royalties, head-office allocations, pricing documentation or the 500 million FCFA threshold. Two cases recompute adjustments and distinguish the documentation boundary from substantive pricing. Administration templates, APA and CbCR implementation, treaty relief and some penalty interpretation remain explicit gaps; this is a partial preparation method."
license: "AGPL-3.0-or-later (code) / OpenAccountants Guide License v1.0 (content)"
metadata:
  source: openaccountants
  openaccountants_url: "https://www.openaccountants.com/skills/td-transfer-pricing"
  jurisdiction: "TD"
  tax_year: "2026"
  last_updated: "2026-11-01"
---

# Chad transfer pricing v1.0

> **General reference only.** This skill is general tax/accounting reference material for AI-assisted workflows. It has not been reviewed for any specific person's facts, documents, elections, deadlines, residency, filing status, or local procedures. Do not rely on it to file, pay, amend, or take a tax position without review by a qualified professional in the relevant jurisdiction.

## Who this applies to

Chad enterprises with foreign related-party transactions or indirect profit transfers within CGI article41. Companies import that rule through article134. The arm's-length adjustment is not switched off merely because documentation thresholds are not met. Article41 also has a privileged-tax-jurisdiction route without the ordinary dependence/control test. This Guide prepares the adjustment and documentation working paper for2026; treaty APAs, country-by-country reporting and implementing forms remain open. [CGI41,134,1000(XIV)](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef); [LF2026 art1](https://ecofinances.gouv.td/wp-content/uploads/2026/06/Loi-n008-AN-SENAT-2025-Portant-loi-de-Finances-2026-LF-2026.pdf#page=1).

## Rates, bands and thresholds

| Rule and conditions | Figure | Official source |
|---|---|---|
| Annual documentation threshold for Chad entity transacting with related foreign legal entities | Annual turnover excluding tax OR gross balance-sheet assets at least500,000,000FCFA | [CGI1000(XIV)](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef) |
| Minimum official response period to the specified information request | One month | [CGI1000(XIV)](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef) |
| Total response period following reasoned extension | At most three months | [CGI1000(XIV)](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef) |
| Inadequate response followed by formal demand |30days to supplement | [CGI1000(XIV)](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef) |
| Late TP documentation, first month |10,000,000FCFA | [CGI1060](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef) |
| Second month |20,000,000FCFA | [CGI1060](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef) |
| From third month, exact statutory formula |25,000,000 and5,000,000FCFA per month of delay | [CGI1060](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef) |

The last row preserves the source's wording. Obtain the assessment's period/cumulative interpretation before calculating a multi-month penalty; do not invent a single accumulated formula.

## The base

1. Draw the ownership/control graph, foreign entity locations and transaction inventory: purchases, sales, services, royalties, finance and cost sharing. Article41 covers direct/common control and indirect transfers through raised/lowered prices or other means; privileged-tax cases need their own statutory test. [CGI41](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef).
2. Reconcile each controlled flow to the accounts, agreements, invoices, delivery/service evidence and payments. Establish the actual functions, assets and risks. A group policy is not transaction evidence and does not itself justify a deduction. [CGI1000(XIV)](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef).
3. Select and explain an arm's-length method and relevant comparables. The local source requires the method, selection, application and relevant comparison analysis; it does not establish a mandatory OECD-method hierarchy. If precise evidence is absent, article41(IV) refers to normally operating comparable Chad enterprises. Do not treat an unsupported comparable as a factual price. [CGI41(IV),1000(XIV)](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef).
4. Recompute the Chad profit effect. Excess purchase/expense price reduces Chad profit, so add the proven excess back; an understated sale calls for adding the proven shortfall. Retain all adjustments and any treaty interaction in the corporate reconciliation. General deductibility, foreign head-office limits and withholding remain separate tests in the [corporate Guide](td-corporate-income-tax.md). [CGI26(XXII),41,134](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef).
5. Apply the threshold using either turnover OR gross assets, including equality. If met and there are the specified foreign related-entity dealings, assemble general group information (activities/changes, legal/operational structure, functions/risks, relevant intangibles, policy and organisation chart) and entity-specific information (activity, nature/amounts of flows, cost-sharing/APAs/rulings, selected methods, functional analysis and comparables). Attach documentation to the DSF with complete TP documentation. Below threshold, keep the substantive article41 support; exemption from this threshold obligation is not a safe harbour for non-arm's-length prices. [CGI1000(XIV)](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef).
6. Reconcile final adjustments into the DSF profit bridge and retain the original working paper, transaction evidence, comparison source and submission record. Do not label the result accountant-attested from this AI review.

## Deadlines and filing

The TP documentation accompanies the annual DSF under article1000(XIV); annual return timing is owned by the [corporate Guide](td-corporate-income-tax.md). Electronic filing follows new996 under LF37. The current administration documentation model, upload boxes and live portal procedure were not acquired: obtain the actual template before filing. [CGI1000(XIV)](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef); [LF37](https://ecofinances.gouv.td/wp-content/uploads/2026/06/Loi-n008-AN-SENAT-2025-Portant-loi-de-Finances-2026-LF-2026.pdf#page=56).

An information request has a response period of at least one month, extendable for reasons up to three months total; an insufficient response triggers a30day formal demand. Record receipt dates, the actual stated deadline and any approved extension, rather than assuming the longest period. Article1000 permits requesting an advance pricing agreement, but this Guide does not supply an acquired APA procedure. [CGI1000(XIV)](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef).

## Penalties and interest

Missing/incomplete required documentation causes rejection of the associated-party charges as deductible expenses under article1000(XIV), in addition to the offence-specific late-documentation amounts above. General tax adjustments can carry the applicable assessment penalties; do not compute them as if a documentation fine settled the underlying tax. Keep principal, rejected charges and procedural sanctions distinct. [CGI1000(XIV),1060](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef).

## Cross-border points

Establish the legal counterpart, place of incorporation, control and actual service before choosing a treaty or collection route. Related-party support does not resolve the conflicting25%/18% foreign-service paragraphs in CGI26, or prove eligibility for a CEMAC or treaty rate. Those payment-specific questions remain held. [CGI26,41,1000(XIV)](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef).

## Two worked examples that recompute

### Excess related-party purchase

A company has documented foreign-related purchases of100million, with a supported arm's-length amount90million. Book profit is80million. Add back10million; adjusted profit is90million before other adjustments. The comparison value is a hypothetical supported input, not a statutory margin.

```oa-check
name: Excess purchase price restores Chad profit
inputs:
  book_profit: 80000000
  booked_purchase: 100000000
  supported_purchase: 90000000
steps:
  addback: max(0, booked_purchase - supported_purchase)
  adjusted_profit: book_profit + addback
expected:
  addback: 10000000
  adjusted_profit: 90000000
```

### Documentation boundary does not decide substantive pricing

A Chad entity's turnover is300million but gross assets exactly500million; it meets the OR/equality documentation threshold. Its related sale recorded60million has a supported value70million. Add10million to80million book profit, producing90million. If assets were490million with the same turnover, the stated documentation threshold would not be met, but the same supported article41 adjustment remains10million. The decision is whether the full documentation obligation attaches, not whether shifting profit is allowed.

```oa-check
name: Same price adjustment across documentation boundary
inputs:
  book_profit: 80000000
  booked_sale: 60000000
  supported_sale: 70000000
steps:
  shortfall: max(0, supported_sale - booked_sale)
  threshold_met_adjusted_profit: book_profit + shortfall
  below_threshold_adjusted_profit: book_profit + shortfall
expected:
  shortfall: 10000000
  threshold_met_adjusted_profit: 90000000
  below_threshold_adjusted_profit: 90000000
```

## Ask the client first

- What ownership/control, entity locations and privileged-tax facts apply?
- What annual turnover and gross assets establish the documentation boundary?
- What foreign controlled flows, agreements and transaction support reconcile to the accounts?
- Which functional analysis, methods, comparables, cost-sharing arrangements, APAs or rulings exist?
- What DSF submissions, information requests, receipt dates and approved extensions exist?

## Sources

| Primary source | Read on | Actual scope |
|---|---|---|
| [Archived ministry official CGI2025, capture2025-07-20](https://web.archive.org/web/20250720004455id_/https://www.finances.gouv.td/index.php/le-ministere/le-ministre/item/download/438_afa372566d4acca63cb857e846d67eef) |2026-11-01| Source researcher and writer read arts26,41,134,1000(XIV),1060 and adjacent request/penalty clauses; group/entity lists,500million OR test, methods and deadlines |
| [Enacted LF2026](https://ecofinances.gouv.td/wp-content/uploads/2026/06/Loi-n008-AN-SENAT-2025-Portant-loi-de-Finances-2026-LF-2026.pdf) |2026-11-01| Art1 continuing collection and art37 new electronic-filing obligation; relevant changes checked against baseline |

Not yet confirmed: current documentation template, upload/payment workflow, APA implementation, CbCR implementation/threshold and treaty mutual-agreement/correlative relief; privileged-tax classification for a particular recipient; exact cumulative interpretation of third-month TP fine and conflicting foreign-service withholding. TP remains partial. For independent AI source review and its limits, see the [country README](README.md). No accountant attestation.

## Today's figures and who stands behind this skill

This file is an AI skill (tax rules your AI follows) from OpenAccountants, copied on 2026-11-01. Rates, thresholds and deadlines change. For the current version of this skill, its official sources and the named accountant (if any) who stands behind it, call `get_skill` with slug `td-transfer-pricing` on the OpenAccountants connector (https://www.openaccountants.com/connect), or read https://www.openaccountants.com/skills/td-transfer-pricing. If neither is available, confirm every figure against the official source pages cited above before relying on it.