Insights & Events
As of June 1, 2023, the United Arab Emirates (UAE) implemented its Federal Corporate Tax (CT) law, marking a significant shift in the tax landscape for businesses operating in the region. This move signifies the UAE’s efforts to align with global tax standards while still maintaining its position as an attractive destination for both local […]
Click to read moreThe line between “foreseeably relevant” tax information and a pure fishing expedition is becoming a live controversy in transfer pricing audits – and a recent UK Tribunal case offers timely lessons for multinationals. For African and ME groups facing increasingly assertive audits, this fact pattern will feel very familiar. What information was requested? HMRC’s( UK tax authority) information notice […]
Click to read moreWhy the consultation paper on the revision to Chapter VII of the OECD Transfer Pricing Guidelines matters for African and Middle Eastern groups Across Africa and the Middle East, one tax issue keeps coming back in audits: management fees and headoffice service charges. Local tax authorities often argue there is “no benefit”, especially when the local entity is […]
Click to read moreThe OECD is developing proposals on the taxation of globally mobile workers, with more concrete outputs expected by the end of 2026.[cite:483][cite:479] The project reflects the growing pressure that cross-border remote work, hybrid arrangements and short-term international mobility place on rules that were designed for a more traditional model of work.[cite:492][cite:497] Why this matters now […]
Click to read moreMost tax professionals assume that if a company provides a guarantee to its parent and charges nothing for it, the tax authorities will come knocking. Italy’s Supreme Court just said: not so fast. On 7 May 2026, Italy’s highest court issued Ordinance No. 13136. An Italian subsidiary had provided guarantees worth roughly EUR 42 million securing a loan for […]
Click to read moreFor years, many investors have bought and sold Kenyan businesses without ever touching a Kenyan share register. The deals were papered in London, Dubai or Mauritius.The value was in Kenya.The tax position was…murky. Finance Bill 2026 is designed to change that. What is an “indirect transfer”? Instead of selling shares in a Kenyan company, an […]
Click to read moreDear Members of Working Party No. 6, I welcome the opportunity to comment on the discussion draft revising Chapter VII of the OECD Transfer Pricing Guidelines, released on 1 June 2026. My comments are confined to Multinational groups operate in an intensely competitive commercial environment in which duplicated cost is not tolerated as a matter […]
Click to read moreIntroduction The Government of the Republic of Zambia, on 30 December 2020, published Statutory Instrument (SI) No. 117 of 2020 whereby it establishes country-by-country reporting regulations. The regulations became effective on 1 January 2021. Consistent with OECD guidelines on appropriate use, the country-by-country (CbC) report will be used by the Commissioner-General for high-level assessment of […]
Click to read moreIntroduction On 18 December 2020, the Organization for Economic Co-operation and Development (OECD) issued its guidance (referred to as the “Guidance”) on the transfer pricing implications of the COVID – 19 pandemic. The Guidance represents the consensus view of the 137 members of the inclusive framework on Base Erosion and Profit Shifting (BEPS) regarding the […]
Click to read moreOn 14th December 2020, Rwanda published Ministerial Order No. 003/20/10/TC of 11 December 2020 in the Official Gazette. The order which comes into force on the date of publication in the Gazette establishes general rules on transfer pricing between related persons involved in controlled transactions and largely conforms with the 2017 OECD guidelines. It empowers […]
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