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Seychelles: DRAFT Transfer Pricing rules – comments till 15 April 2015

Section 54 of the Business Tax Act 2009 states as follows:
54.(1) The Revenue Commissioner may, in respect of —
(a) a transaction between businesses carried on by persons who are associates;
(b) a transaction between businesses carried on by the same person,
distribute, apportion, or allocate income or gain and expenses between the businesses as is
necessary to reflect the outcome that would have arisen in a transaction between independent
persons dealing with each other at arm’s length.
(2) In applying subsection (1), the Revenue Commissioner may be guided by international
standards, case law, and guidelines on transfer pricing issued by international organization
concerned with taxation.

Applicable transfer pricing methods
10. Even though a taxpayer is free to choose its own transfer pricing method (refer paragraph 23 below),
the Revenue Commissioner assess the following transfer pricing methods (in preferential order), as
being largely appropriate for use:
a) the comparable uncontrolled price method
b) the resale price method
c) the cost plus method
d) the transactional profit split method or,
e) the transaction net margin method