East Africa; Did BEPS End Tax Avoidance or Simply Relocate…
Reflections on the East African experience since the publication of the BEPS Actions, the rise of aggressive transfer pricing enforcement,…
Managing the Upstream; Rethinking Cross Border Tax and Transfer Pricing…
The Paradigm Shift: Upstream Framework vs. Downstream Audits In East African tax regimes, a Transfer Pricing (TP) audit is widely…
Rethinking Cross-Border Financing Arrangements
Introduction Cross-border intercompany financing arrangements have long served as a fundamental pillar of capital allocation strategies within Multinational Enterprises (MNEs).…
The Tested Party in Transfer Pricing
In cross-border commercial and financial transactions between associated enterprises, applying a transfer pricing method requires an objective, robust, and verifiable…