Effectiveness of Transfer Pricing Audit on Tax Compliance Among Large Taxpayers in Tanzania
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This study investigated the effectiveness of transfer pricing audits in enhancing tax compliance among large taxpayers in Tanzania, focused on intra-group services and intra-group financing transactions. The study is motivated by the complex operational structures of multinational enterprises (MNEs), which enable profit shifting through manipulated intra-group transactions, thus eroding the Tanzanian tax base. In response, Tanzania implemented Transfer Pricing Regulations in 2018, empowering the Tanzania Revenue Authority (TRA) to conduct targeted audits under the Large Taxpayers Department (LTD).Using a descriptive and inferential quantitative approach, the study systematically sampled 52 tax auditors from a population of 60 TRA officers using Yamane’s formula. Data were collected via structured questionnaires capturing perceived compliance levels for three consecutive years (2020–2022) following audit detections and penalties in 2019. Analysis was conducted using SPSS for descriptive statistics and Microsoft Excel for trend visualization. Descriptive results revealed that compliance likelihood in intra-group services peaked in 2020 at 85.7% but declined to 61.3% in 2021 and further to 32.7% in 2022. Similarly, intra-group financing compliance declined from 77.6% in 2020 to 59.2% in 2021 and dropped sharply to 24.5% by 2022. This trend indicates that audit interventions initially promote compliance but lose their impact over time without further regulatory reinforcement. The study concludes that transfer pricing audits exert a strong short-term influence on tax compliance among large taxpayers, particularly in the first-year post-audit. However, the declining compliance trend suggests the need for continuous and strategic audit interventions. It recommends that TRA increase audit frequency, strengthen audit capacity through technology and training, and implement sustained taxpayer engagement strategies to support lasting compliance gains.
Advani, A., Elming, W. & Shaw, J. (2021). The Dynamic Effects of Tax Audits. The Review of Economics and Statistics, 1–45.
Agosto, E., Manzo, M., Modica, A., & Pisani, S. (2017). Tax Audits and Tax Compliance—Evidence from Italy. https://www.irs.gov/pub/irs-soi/17resconmodica.pdf
Ali, M., Fjeldstad, O., & Sjursen, I. (2014). To Pay or Not to Pay? Citizens’ Attitudes Towards Taxation in Kenya, Tanzania, Uganda and South Africa.
Allingham, M.G. & Sandmo, A. (1972). Income Tax Evasion: a Theoretical Analysis. Journal of Public Economics, 1(3–4), 323–338.
Alm, J., & McClellan, C. (2012). Tax Morale and Tax Compliance from the Firm’s Perspective. Kyklos, 65(1), 1–17.
Alm, J., Jackson, B.R., & McKee, M. (2009). Getting the Word Out: Enforcement Information Dissemination and Compliance Behavior. Journal of Public Economics, 93(3–4), 392–402.
Barker, J., Asare, K., & Brickman, S. (2016). Transfer Pricing As A Vehicle In Corporate Tax Avoidance.
Beebeejaun, A. (2018). The Efficiency of Transfer Pricing Rules as a Corrective Mechanism of Income Tax Avoidance. Journal of Civil & Legal Sciences, 7(1). https://doi.org/10.4172/2169-0170.1000237
Bhatachargee, S., & Baid, K. (2018). Tax as A Major Source of Government Funding in India.
Chalu, H., & Mzee, H. (2018). Determinants of Tax Audit Effectiveness in Tanzania. Managerial Auditing Journal, 33(1), 35–63.
Chatama, Y.J. (2013). The Impact of ICT on Taxation: the Case of Large Taxpayer Department of Tanzania Revenue Authority.
Chege, A., Kiragu, N., Lagat, C. & Muthoni, G. (2015). Effect of Electronic Fiscal Devices on VAT Collection in Tanzania: A Case of Tanzania Revenue Authority.
Clement, O. & Temitope, E. (2018). Effects of Tax Audit on Tax Compliance in Ekiti State, Nigeria. European Journal of Accounting, Auditing and Finance Research, 6(5).
Devos, K. (2014). Factors Influencing Individual Taxpayer Compliance Behaviour. Springer.
Ebrahim, A., Kisanga, E., Swema, E., Leyaro, V., Mhede, E. P., Mdee, E., Palviainen, H., & Pirttilä, J. (2021). The Effects of a Risk-based Approach to Tax Examinations: Evidence from Tanzania. WIDER Working Paper 2021/150.
Feld, L. P., & Frey, B. S. (2002). Trust Breeds Trust: How Taxpayers Are Treated. SSRN Electronic Journal. https://doi.org/10.2139/ssrn.263351
Han, X., Omer, T. C., Wu, L., Xing, Q., & Zhou, J. (2022). Audit Effort and Tax Avoidance: Evidence from China. SSRN Working Paper.
ITD. (2010). Revenue Administration in Sub-Saharan Africa: Comparative Information Series No.1. http://www.itdweb.org/documents/AfricaStudy.pdf
Kar, D., & Cartwright-Smith, D. (2008). Illicit Financial Flows from Developing Countries: 2002–2006. Global Financial Integrity.
Kasper, M., & Alm, J. (2020). Audits, Audit Effectiveness, and Post-audit Tax Compliance. Tulane University Working Paper.
Lisowsky, K. K., & Mescall, D. (2017). Transfer Pricing: Strategies, Practices and Tax Minimization. Contemporary Accounting Research, 34(1), 455–493.
Lohse, T. & Riedel, N. (2012). The Impact of Transfer Pricing Regulations on Profit Shifting. FZID Discussion Paper No. 1-2012.
Lohse, T., & Riedel, N. (2012). The Impact of Transfer Pricing Regulations on Profit Shifting Within European Multinationals. FZID Discussion Paper, No.1–2012.
Mashiri, E., Dzomira, S., & Canicio, D. (2021). Transfer Pricing Auditing and Tax Forestalling by Multinational Corporations: A Game Theoretic Approach. Cogent Business & Management, 8.
McCluskey, W., & Huang, C. (2019). The Role of ICT in Property Tax Administration: Lessons from Tanzania.
Melnychenko, R., Pugachevska, K., & Kasianok, K. (2017). Tax Control of Transfer Pricing. Investment Management and Financial Innovations, 14(4), 40–49.
OECD (2013, 2015). Action Plans on Base Erosion and Profit Shifting. OECD Publishing.
OECD. (2004). Compliance Risk Management: Managing and Improving Tax Compliance. Guidance Note.
OECD. (2015). Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations.
Pallant, J. (2020). SPSS Survival Manual: A Step-by-Step Guide to Data Analysis Using IBM SPSS. 7th Edition. McGraw-Hill Education.
Prichard, W., Custers, A., Dom, R., Davenport, S., & Roscitt, M. (2019). Innovations in Tax Compliance: Conceptual Framework. World Bank.
Safaei, E., Sureth, R., & Wu, C. (2021). Are Risk-Based Tax Audit Strategies Rewarded? ARQUS Discussion Paper No. 267.
Sebele-Mpofu, F.Y., Mashiri, E., & Warima, S. (2022). Enhancing the Effectiveness of Transfer Pricing Regulation Enforcement. Journal of Accounting Finance and Auditing Studies.
TRA. (2020). Tanzania Revenue Authority Annual Report.
URT. (2019). The Tanzania Revenue Authority Act [Principal Legislation] Revised Edition 2019.
World Bank (2015). Tax Reforms Are Necessary to Help Tanzania Finance Development and Solidify Economic Growth.
Yamane, T. (1974). Statistics: An Introductory Analysis. 3rd Edition. Harper and Row.
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