Selling is only half the goal

For a foreign manufacturer, success in Tanzania isn’t just sales. It’s profit that reaches the group, at a tax cost you planned for, without a dispute years later.

That depends on decisions made early: what price your Tanzanian business pays for products, what fees it pays the group, and how money moves out. Get them right, and the structure runs quietly. Get them wrong, and the cost often surfaces long after the decisions were made.

The real worry

Most group finance teams aren’t worried about the tax rate. They’re worried about the assessment that arrives three years later, challenging prices and fees they thought were settled, with interest and penalties on top.

Here’s how profit is taxed on its way from Tanzania, and where the risks sit.

Four points where tax applies

1. At the border

Item

Rate

Import duty on pharmaceuticals

0%

VAT on imports

18% standard rate, unless the product qualifies for exemption

TMDA importation fee (regulatory)

2% of FOB value

What it means: border costs for medicines are low, but they depend on correct product classification. The value you declare at the border also matters for the next point.

2. In the Tanzanian company

Item

Rate

Corporate income tax

30%

New pharmaceutical manufacturer with a Government performance agreement

20% for the first five years of production

Minimum tax after three consecutive years of tax losses

0.5% of turnover

What it means: a subsidiary that reports losses year after year doesn’t escape tax. After three years, it pays tax on turnover, and the losses themselves invite questions about its prices.

3. On the way out

Payment to a foreign group company

Withholding tax

Dividends

10%

Royalties

15%

Service and management fees

15%

Interest

10%

A tax treaty between Tanzania and your home country may reduce some of these rates, if the conditions are met.

4. Across all of it: transfer pricing

Every price between your group companies (for products, brands, services and loans) must be at arm’s length: what independent companies would agree. This is where most disputes start.

Transfer pricing: where the risk really sits

The common pattern: a subsidiary buys products from its parent at a high price, pays royalties and management fees on top, and reports little or no profit in Tanzania.

To the tax authority, that looks like profit shifted out of the country. The usual result is that prices or fees are adjusted, deductions are refused, and tax, interest and penalties are assessed for past years.

A better approach for most distributors: structure the Tanzanian company as a limited-risk distributor that earns a modest, stable profit, backed by documentation showing why that profit is right for its role.

One insight often missed: product prices affect more than income tax. A higher transfer price raises the value declared at the border, which increases VAT and the 2% import fee, and reduces local profit. A lower price does the opposite. The right price balances all of these, and stays consistent across customs, income tax and transfer pricing records.

Choosing how money comes home

Route

Withholding tax

What to watch

Dividends

10%

Paid from taxed profit, so there’s no deduction locally, but simple and low-risk

Royalties

15%

Must reflect real value from the brand or technology; heavily scrutinized

Service fees

15%

Services must actually be provided and documented

Interest

10%

The loan and rate must be commercial

The best mix depends on your group’s tax position. Royalties and fees stacked on top of a high product price are the combination most likely to be challenged.

Where companies get stuck

  • Years of losses. A subsidiary reported losses for several years. The tax authority adjusted its product prices, and the company also paid minimum tax on turnover.
  • Fees without evidence. Management fees were charged every year, but no one could show which services were provided. The deductions were refused.
  • Customs and tax told different stories. The value declared at the border didn’t match the transfer pricing documentation, which raised questions on both sides.
  • No documentation. Prices were reasonable, but there was nothing on file to prove it, so the company couldn’t defend its position when audited.

What a good tax structure looks like

  • A clear role for the Tanzanian company, with a profit level that matches it.
  • Prices and fees that are consistent across customs, income tax and transfer pricing.
  • Documentation ready before anyone asks for it.
  • Treaty benefits used where available.
  • Incentives secured if you manufacture locally.
  • A predictable effective tax rate, so the board knows what reaches the group.

That’s the goal: profit that comes home on time, at a cost you planned for, with nothing waiting to surface later.

How Glenrich helps

Tax for a cross-border pharmaceutical business means income tax, customs, withholding and transfer pricing working together. Glenrich brings them into one plan. Our tax, investment advisory and risk teams guide you in three steps:

  1. Design the structure. We define the Tanzanian company’s role, set prices and fees, and model your effective tax rate and the cash that reaches the group.
  2. Document and defend. We prepare transfer pricing documentation, keep customs and tax positions consistent, and support you in any review.
  3. Manage it every year. We handle filings and withholding tax, monitor results against your policy, and give your head office clear reporting.

Planning your Tanzanian tax structure? Let’s talk.

We work with international clients by video call, in English, around your time zone.

Book a free introductory call

Glenrich Consultants, Samora Tower, Dar es Salaam

Frequently asked questions

Is there import duty on medicines in Tanzania?
Import duty on pharmaceuticals is 0%. VAT and the TMDA importation fee may still apply.

What is the corporate tax rate for pharmaceutical companies?
30% generally. New pharmaceutical manufacturers with a Government performance agreement pay 20% for their first five years of production.

What withholding tax applies to payments to a foreign parent?
10% on dividends and interest, and 15% on royalties and service fees, subject to any tax treaty.

What happens if my Tanzanian subsidiary keeps making losses?
After three consecutive years of tax losses, a minimum tax of 0.5% of turnover applies, and persistent losses often prompt a transfer pricing review.

Further reading

About Glenrich

Glenrich Consultants is a finance and risk partner for investors and businesses in Tanzania. Our team of accountants, tax consultants, investment advisors and risk specialists supports clients from market entry through to compliance, reporting and protection, across Tanzania Mainland and Zanzibar.