Best Practices for Developing & Maintaining Audit-Ready Intercompany Agreements For MNEs
The establishment of suitable Intercompany Agreements (ICAs) is a continuous initiative rather than a singular undertaking. This is attributable to the dynamic nature of the group’s composition, subject to alterations resulting from acquisitions, organic growth, or organizational reconfiguration. Additionally, the group must periodically revise its Transfer Pricing (TP) compliance strategies due to modifications in tax...
The Significance of Intercompany Agreements (ICAs) in Transfer Pricing Compliance
Intercompany agreements, or ICAs, are legal contracts entered into between businesses with similar interests. These agreements lay the groundwork for the legal structure that governs the provision of services, products, intangible assets, and financial assistance inside a corporate group. Management services, administrative and other back-office services (e.g., finance, tax, legal, and HR services), marketing services,...
Understanding Controlled Foreign Company (CFC) Rules for Multinationals
Controlled Foreign Company (CFC) rules are tax laws that are designed to prevent multinational companies from shifting profits to subsidiaries located in low-tax jurisdictions in order to avoid paying taxes in their home country. These rules aim to ensure that multinational companies pay their fair share of taxes on the income generated by their foreign...
Fair Taxation For Multinational Companies: Simplifying The STTR Rule (Prt 1)
The STTR rule, part of the Inclusive Framework on BEPS, helps countries fairly tax multinational companies. It’s one of the rules under Pillar Two, which allows countries to tax certain payments when other countries don’t tax them enough. The STTR focuses on preventing companies from dodging taxes by moving their profits to countries with very...
Ethiopia Capital Markets Stakeholders Mapping: The ECMA & ESX
Capital markets play a critical role in efficient and arguably effective allocation of scarce financial resources to competing investment opportunities in a given economy. They also provide an alternative source of capital for the private and public sectors in countries where they are well established. Capital markets complement the traditional sources of capital for businesses...
From Fields To Factories: Agrarian Revolution To Fourth Industrial Revolution (4IR)
The progression from the Agrarian Revolution to the Fourth Industrial Revolution represents pivotal milestones in human history, marked by profound shifts in technology, economics, and society. To provide a comprehensive understanding of these transformative periods, we offer the following summary: Agrarian Revolution (circa 10,000 BCE): The Agrarian Revolution, also known as the Neolithic Revolution, marked...
Charting A Course For Sustainable Growth: Kenya Medium-Term Revenue Roadmap – Prt 2
Tax Policy Changes Value Added Tax Firstly, there is a proposal to review the VAT threshold, aiming to optimize operational efficiency within the VAT system. Reviewing the VAT threshold can enhance efficiency by streamlining the administration of VAT, potentially reducing compliance burdens for small businesses. Secondly, a comprehensive assessment of exempt and zero-rated supplies is...
Charting A Course For Sustainable Growth: Kenya Medium-Term Revenue Roadmap – Prt 1
A medium-term revenue strategy (MTRS) is a high-level roadmap for tax system reform, covering a period of four to six years. Tax reform includes changes to tax policy, tax administration and legal frameworks. According to PCT 2017, the core elements of the MTRS Includes; A social contract on the level of revenue mobilization effort for...
Green Protectionism: Balancing Environmental Concerns and Trade Interests
The Dynamics of Protectionism Trade has long been considered a cornerstone of economic prosperity, fostering growth and development in societies across the globe. However, the concept of protectionism, which involves implementing trade barriers to shield domestic industries from foreign competition, has also played a significant role in shaping economic policies. Protectionism, including tariffs, import quotas,...