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ATAF strengthens Namibia’s capacity in Transfer Pricing audits

Simon Osuji by Simon Osuji
September 15, 2025
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ATAF strengthens Namibia’s capacity in Transfer Pricing audits
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Windhoek, Namibia – 25–29 August 2025

ATAF conducted a high-level technical support mission to the Namibia Revenue Agency (NamRA), focusing on strengthening Namibia’s capacity in transfer pricing audits within the mining sector.

Over the course of the mission, ATAF’s experts worked alongside NamRA auditors on seven active cases, providing advanced guidance on audit methodologies, cross-border pricing reviews, and sector-specific valuation of mining assets. This direct collaboration is enhancing Namibia’s ability to address complex tax challenges in a sector central to its economy.

In addition, ATAF supported NamRA’s legal team and the Ministry of Finance in reviewing tax policy frameworks to ensure multinational corporations — particularly those engaged in Offshore Indirect Transfers (OITs) — are taxed fairly and effectively.

This mission builds on ATAF’s broader impact in Namibia. Over recent years, ATAF’s technical assistance has directly shaped reforms such as the drafting of the 2023 Transfer Pricing legislation and the Income Tax Amendment Act of 2024, which introduced stronger compliance rules, interest limitation provisions, and digitalised processes. These reforms have boosted taxpayer compliance and improved revenue outcomes, with one major company declaring over N$200 million in provisional tax for the first time. ATAF has also enhanced NamRA auditors’ analytical capacity, enabling them to uncover additional risks, strengthen audit efficiency, and develop practice notes that align with international standards.



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