Fie Insights

The Kenyan taxation framework operates on a self-assessment basis, susceptible to manipulation, filing errors, income understatement, and expense overstatement, among other vulnerabilities. To comprehend the foundation of this system, it is essential to explore the underlying legal framework. Under the Judicature Act (CAP 8), the High Court, Court of Appeal, and subordinate courts are mandated...

Introduction According to a guide developed by the International Institute for Sustainable Development (IISD), the Pillar Two Global Anti-Base Erosion (GloBE) minimum tax proposal will have an impact on numerous countries, regardless of whether they take action within their own borders. The GloBE initiative establishes a reservoir of potential tax revenues from the incomes of...

Energy and Resource (ER) Transfer Pricing Considerations Trading Hub: In the present BEPS landscape, the focal point regarding trading hubs revolves around a crucial transfer pricing (TP) consideration. It involves ensuring a harmonious correlation between two key factors: Strategic Decision-Making and Risk Control: This entails verifying that the geographic location where pivotal decision-makers exert authority...

Transfer price is the price of a transaction between two entities that are part of the same economic group of companies. The price transacted between the two related entities is the “transfer price” and the process for setting the price is referred to as “transfer pricing.” Whereas commercial transactions between independent enterprises are generally determined...

The report on Crypto-Asset Reporting Framework (CARF) and Amendment to the Common Reporting Standard (CRS) was released to the public by Organization for Economic Cooperation and Development (OECD) in the month of October 2022. This comes at a time where OECD recognizes the need to address Crypto assets which can be transferred and held without...

According to Finnerty in 2007, International tax law framework has been used to indicate a set of rules that affect the tax treatment of cross-border operations. This set of rules is constituted primarily by domestic tax rules, whose application is generally limited by double tax treaties and other international law instruments. In Kenya for instance,...

BAPA process has been well elaborated and articulated in the Bilateral Advance Pricing Arrangement Manual. However, it only acts as a guidance on the best practices to approach the process and should not be construed as an advice but an awareness on the whole spectrum. The following stages has been suggested to guide the BAPA...

In the advent of globalization, new emerging business models have developed in the last 10 years with the recent developments heavily experienced in the financial products and intermediaries such as Decentralized Finance (DeFi). At the same time jurisdictions globally are concerned about the potential growth of digital economy and the risks associated with reduced transparency...