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…
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).…
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…
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,…