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April 16, 2024 Algerian Finance Ministry offers clarity on transfer pricing documentation and determining depreciation period for fixed assets In its efforts to provide more clarity to the taxpayers, the Algerian Ministry of Finance has published two critical orders: the Order of 15 February 2024, determining the content and format of transfer pricing documentation, and the Order of 25 February 2024, aimed at setting the depreciation period for fixed assets, applied to determine taxable income. Order on transfer pricing documentation The 15 February order provides the content requirements for transfer pricing documentation to be presented during a tax audit, which should include (i) information relating to the group of related parties and (ii) information about the company subject to the tax audit. The information relating to the group of related parties to which the company subject to a tax audit belongs must include:
The information related to the company subject to a tax audit includes:
The documentation must be submitted in paper and electronic format in one of the languages used by the tax authorities (French or Arabic). Order setting depreciation period for fixed assets An order has been issued setting the depreciation period for tangible and intangible fixed assets recorded in the balance sheet as of the fiscal year ending in 2023, applicable for the determination of the taxable income in accordance with the provisions of Article 141 of the Direct Taxes Code. The depreciation period for fixed assets is initiated as follows:
The tax depreciation period for intangible fixed assets ranges from two to five years, and the tax depreciation period for tangible fixed assets the latter ranges from three to 100 years. The following table provides some examples of the depreciation life of certain fixed assets:
*ERP refers to enterprise resource planning. The provisions of the order shall not apply to fully depreciated fixed assets shown as assets in the balance sheet for year ended in 2023.
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