Mozambican legislation on transfer pricing, in force since December 2007, aims to guarantee fairness in transactions between related companies and to ensure fair taxation of Corporate Income Tax. (IRPC). The Transfer Pricing Regulation (RPT) was implemented to fill gaps in the legislation, allowing for a more structured approach.

However, contracts in the gas sector still violate transfer pricing regulations, allowing for differentiated prices for affiliated and non-affiliated companies. This persistent practice, even after 2007, represents a substantial risk to tax revenues. Furthermore, contractual addenda have increased the price discrepancy, reinforcing the violation of transfer pricing law.

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