Transfer pricing - Libya

Global transfer pricing guide

01 Jan 2025 1 min read

This publication provides a high-level overview of Libya's transfer pricing rules and outlines who to contact for expert guidance in this area.
Contents

Introduction to transfer pricing in Libya

  • Although Libya does not have formal transfer pricing rules, the tax department has the authority to assess tax on a deemed profit basis under general anti-avoidance provisions where a transaction appears not to be on the arm’s length terms.

  • For arrangements involving jurisdictions that have a Double Tax Treaty with Libya, the OECD Transfer Pricing Guidelines should be considered, as Libya follows the OECD model.

  • None yet.

Transfer pricing documentation

  • No requirements in place yet.

  • No requirements.

  • Transactions conducted with related parties that operate in low tax jurisdictions (tax paradise).

  • Persistent losses in any entity can be a reason of a full tax audit with a risk of potential significant tax adjustment.

  • Tax deductions for intra-group head office charges and interest rates on intra-group loans are capped by tax regulations.

  • No penalties.

Advance Pricing Agreements (APAs), dispute avoidance and resolution

  • There is no APAs in Libya.

Exemptions

  • Generally, no exemptions from a TP perspective.

Related developments

  • No specific TP provisions in relation to Covid-19. 

Contact us

For further information on transfer pricing in Libya please contact:

Wayne Pisani
Partner – Head of Tax, Technology & Compliance | ILD

T: +356 20931602

E: wayne.pisani@mt.gt.com 

Michael Agius
Director– Tax

T: +356 20931610

E: Michael.agius@mt.gt.com 

Lara Cutajar
Senior Manager – Tax

T: +356 20931611

E: lara.cutajar@mt.gt.com 

 

Luke Aquilina
Manager – Tax & Transfer Pricing

T: +356 20931000

E: luke.aquilina@mt.gt.com 

 

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