Analysis · UEMOA zone · Tax

Transfer Pricing in the UEMOA Zone: What Every CFO Should Know in 2026

Côte d'Ivoire's 2026 fiscal annex reverses the burden of proof in transfer pricing audits and creates an advance pricing agreement mechanism — while Senegal runs a more codified, threshold-driven regime next door. What this means for a group's documentation strategy across the zone.

Direct answer. Yes — the single most consequential transfer pricing change for CFOs operating in the UEMOA zone in 2026 is a reversal of the burden of proof introduced in Côte d'Ivoire under the 2026 fiscal annex. A taxpayer under transfer pricing audit must now demonstrate, from the outset, that intragroup pricing is at arm's length — the tax administration no longer bears that burden. Coupled with a new advance pricing agreement mechanism, and with Senegal's more codified, threshold-driven regime next door, groups with recurring intragroup flows through Abidjan or Dakar face two materially different evidentiary postures within a single monetary zone.

Legal basis

In Côte d'Ivoire, Article 25 of the 2026 fiscal annex (Loi de Finances n° 2025-987 of 19 December 2025), titled "Aménagement du dispositif de contrôle des prix de transfert", reinforces the obligation to produce documentation specific to intragroup international transactions and, critically, reverses the burden of proof onto the taxpayer during a transfer pricing audit. Article 23 of the same annex, "Institution d'un mécanisme d'accord préalable sur les prix en matière de prix de transfert", creates for the first time an advance pricing agreement between a taxpayer and the tax administration, concluded for a renewable term of three to five years, subject to annual compliance reporting. Neither article, however, codifies a numerical threshold or a closed definition of the lien de dépendance — the relationship of dependency that triggers scrutiny in the first place — and the administration continues to rely on a bundle of factual indicators, a gap practitioners have long flagged in the local press.

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Ehorodou Joris Benjamin Bekoin — Co-Founding Partner · President
OHADA law, UEMOA taxation, M&A, due diligence, certified DPO
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