Transfer pricing : Forvis Mazars at the forefront in Africa

As African tax authorities reinforce their focus on transparency, compliance and cross-border transactions, Forvis Mazars advocates for transfer pricing approaches that combine international standards with practical, locally adapted solutions. The group’s expertise spans key sectors including energy, financial services, telecommunications and consumer goods, enabling it to support clients operating across multiple jurisdictions.

Through its presence across the continent, Forvis Mazars also promotes closer collaboration between businesses and tax administrations, while encouraging the use of technology and capacity building to enhance tax governance and reduce disputes. For the group, effective transfer pricing frameworks are essential to supporting sustainable investment, fiscal stability and long-term economic growth in Africa.

3 questions to Charl Hall, Director at Forvis Mazars in South Africa and Chair of the TP Minds Africa 2026 Conference

Question 1 : What are the biggest challenges companies face when implementing transfer pricing policies across Africa ?

Comparable information and the use of comparable data remains a challenge across Africa. Coupled with this the diverse approach to transfer pricing and the varying legislation across Africa is a challenge for multinationals trading across various jurisdictions. Multinationals must continue to navigate fragmented transfer pricing rules while balancing OECD/UN Guidelines with local jurisdictional adaptions.

Question 2 : How is digitalisation impacting transfer pricing frameworks in Africa and how is Forvis Mazars helping its clients ?

Digitalisation is reshaping transfer pricing in Africa with an increased transparency in data, enabling real-time audits and increasing scrutiny on intangibles and digital business models. Forvis Mazars is helping clients by combining global expertise with local insights, leveraging off technology-driven tools and offering tailored advisory and compliance solutions across Africa.

Question 3 : What advice would you give to businesses expanding into Africa ?

Transfer pricing should be a central consideration when expanding into Africa, with strategies ideally designed and implemented at the outset to avoid retrospective adjustments. Africa is not a single market and each country has its own and unique economic, cultural and regulatory environments which together feed into the evaluations for transfer pricing applications within a multinational business.