Impact of Transfer Pricing Arrangement on Public Private Partnerships (PPPs)
Public-private partnerships (PPPs) have become a widely utilized form of infrastructure development across numerous nations globally. By combining the capabilities of public and private entities, efficient and sustainable infrastructure projects can be achieved. One potential issue that could potentially impede the success of these PPP projects is transfer pricing. Transfer pricing is a method of...
Global Ant-Base Erosion (GloBE) Model Rules Pillar Two and Its Implications
The GloBE rules pillar two has been designed to reduce profit shifting and tax competition among countries racing to the bottom. It has also been developed as part of the solution for addressing the tax challenges of the digital economy. As a background Organization for Economic Cooperation and Development (OECD) Pillar 1 and 2 statement...
The Nexus Around International Legal Framework And Transfer Pricing Approach
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,...
Bilateral Advance Pricing Arrangement (BAPA) Process Overview
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...
Emerging Digital Assets And Their Adaptation to Tax Regimes
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...
Role of Green Investment Banks in Scaling Up Climate-Smart Investments – Part 2
The need for innovative and bold solutions to implement new technologies on a large scale is evident. Green Banks have been developed with this purpose in mind, raising and blending capital to finance local climate infrastructure while driving a surge in private investment. These institutions can play a significant role in mobilizing finance to support...
Role of Green Investment Banks in Scaling Up Climate-Smart Investments – Part 1
Countries must invest in and build clean and resilient infrastructure for the world to address the climate crisis and develop equitably. National goals to transform energy use and deploy low-carbon solutions across sectors require investment in projects at the local level. Governments are struggling to source and subsequently deploy sufficient levels of funding for high-priority,...
Quantifying The Economic Costs of Climate Change Across Sectors
Climate change is a pressing global concern that poses a significant threat to economic prosperity. The economic costs of climate change can be felt in various industries and sectors, and have a notable impact on global GDP. According to a 2018 report by the Global Commission on the Economy and Climate, failure to take action...
Two Lakes Packaging Services V. Commissioner for Domestic Taxes: TAT Appeal No. 420 of 2021
Background The Appellant is a registered taxpayer whose principal business is grading and packaging of flowers for export. It is located in Naivasha Kenya. The Respondent is a principal officer of Kenya Revenue Authority, Kenya Revenue Authority is an agency established under the Kenya Revenue Authority Act for the collection of Government revenue and related...