Across the last twelve months we have observed a quiet but unmistakable shift in the way the Tanzania Revenue Authority is approaching transfer-pricing reviews of multinational subsidiaries. The interviews are longer, the document requests broader, and the threshold for closing a file without an adjustment has risen.
The shift is not signalled in any new circular. It is the cumulative effect of better internal data, more experienced controversy officers, and an explicit intra-departmental KPI on yield per audit. Finance leads who treated 2024 as the high-water mark are likely to be surprised by 2026.
Our advice for groups with cross-border related-party flows is unglamorous: invest a quarter in benchmarking documentation that will hold up to a full functional analysis. We are, as always, happy to triage a draft and tell clients candidly whether it is ready.