1887

Botswana

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Botswana can legally issue the following three types of rulings within the scope of the transparency framework: (i) preferential regimes; With respect to the following preferential regime: International financial services company. (ii) cross-border unilateral APAs and any other cross-border unilateral tax rulings (such as an advance tax ruling) covering transfer pricing or the application of transfer pricing principles; and (iii) permanent establishment rulings.

This peer review covers Botswana’s implementation of the BEPS Action 5 transparency framework for the year 2018. The report has four parts, each relating to a key part of the ToR. Each part is discussed in turn. A summary of recommendations is included at the end of this report.

This report is Botswana’s first annual peer review report. Consistent with the agreed methodology this report covers: (i) the domestic legal and administrative framework, (ii) the exchange of information framework as well as (iii) the appropriate use of CbC reports. There is no filing obligation for a CbC report in Botswana yet.

Starting in the late 1990s Botswana has made concerted efforts to attract FDI into export-oriented manufacturing and services, so as to reduce reliance on diamond exports and to diversify its supply-side capacities. Given that indications are that Botswana’s diamond mines will be depleted within the next 20 years, diversification is becoming indispensable to safeguard growth, development and fiscal sustainability. Today the reform efforts of the authorities are consolidated under the Economic Diversification Drive (EDD), which emphasises the critical role to be played by the private sector in stimulating balanced and sustainable growth.

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