Macau: local rules

Macau has transfer pricing rules from 1 January 2026. Law No. 24/2024, which also approved the new Tax Code (Código Fiscal), added articles 43-A to 43-I to the Complementary Tax Regulations (Law No. 21/78/M). Administrative Regulation No. 11/2025 sets the detailed rules and applies to controlled transactions from 1 January 2026. The rules cover transactions between a Macau taxpayer and a related party in another tax jurisdiction; transactions between two Macau taxpayers are outside them. Related parties include a holding of 50% or more of capital or votes, common control, control of most of the board, and any other influence that changes the terms. Complementary tax is charged at up to 12%.

A taxpayer whose controlled transactions reach MOP 10m in a year must attach a summary table of them to its complementary tax return. A master file is needed if annual controlled transactions exceed MOP 1bn, or if the taxpayer had controlled transactions and its group's ultimate parent prepared a master file. A local file is needed if controlled transactions exceed any of: MOP 200m (tangible assets), MOP 100m (financial assets), MOP 100m (intangibles) or MOP 40m (all other transactions). The documents must be prepared within 9 months after the end of the financial year, kept for 7 years, and handed to the Bureau within 15 days of a request. Documents in a non official language must be translated into Chinese or Portuguese unless the Bureau waives this.

The law lists comparable uncontrolled price, resale price, cost plus, profit split and transactional net margin. Other methods can be used if these do not give a reliable answer. Each controlled transaction is tested on its own unless transactions are closely linked. The regulation has special rules for cost sharing, intragroup services, intangibles, restructurings and financing. If the result is outside the range and the taxpayer has not adjusted, the Bureau can adjust it up to at least the median of a three year interquartile range.

Failing to prepare or keep the transfer pricing documents (art. 43-D) is fined MOP 10,000 to 100,000, or MOP 100,000 to 200,000 if deliberate. Failing a CbC duty (notification, report or record keeping) is fined MOP 100 to 10,000, or MOP 1,000 to 20,000 if deliberate. A missing or wrong complementary tax return is fined MOP 100 to 10,000, or MOP 1,000 to 20,000 if deliberate. If documents are not handed over on time, the Bureau can also adjust the taxable profit for that year.

Macau has not enacted Pillar Two. The Complementary Tax Regulations have no amendment after Law No. 24/2024, which did not add a minimum tax, and no Macau minimum tax law was found in the Official Gazette up to issue 43 of 2026. No Pillar Two filing is shown.

Group B taxpayers file the complementary tax return (form M/1) from January to March, and Group A taxpayers (with accounts signed by a registered accountant or auditor) from April to July (April to June before 2026). This tool shows 31 March, the earliest date. A deadline that ends on a day the Bureau is closed moves to the next working day (Administrative Procedure Code art. 74, applied by Tax Code art. 5). A Macau ultimate parent of a group with consolidated revenue of MOP 7bn or more in the previous year must notify the Bureau within 3 months and file the CbC report within 12 months after year end. Unilateral advance pricing arrangements of up to 5 years are available for controlled transactions of MOP 40m or more a year, for a fee of 0.2% of the transactions (capped at MOP 200,000).