Fie Insights

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Tax law

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...

taxation

In our previous thought leadership, we explored why developing economies in Africa should tap into private sector and sovereign funds to finance their Nationally Determined Contributions (NDCs). Development of climate resilient infrastructure will play a key role in climate risks mitigation and adaptation going into the future; hence there is a need to widen the...

Bank

The LIBOR rate was believed to be a true reflection of the markets’ cost of borrowing funds independent of government interference. However, investigations by regulators and journalists after the financial crisis revealed that LIBOR had been manipulated by the banks themselves and at times from influence of regulators. Banks had an interest in keeping the...

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The Profit Split Method: it logically follows that the residual profits will be allocated to those entities contributing the unique and valuable intangibles and making the crucial strategic decision (entrepreneurs), while entities performing supporting functions will be allocated a small and stable (routine) remuneration. The aim is aligning profits with value contribution. It is useful...

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Transactional Profit Methods The Transactional Net Margin Method (TNMM): Net Margin data derived from uncontrolled transactions. TNMM examines the net profit relative to an appropriate base like costs (Net Profit return to Costs), sales (Net Profit return to Sales), or assets (Net Profit Return to Assets). It operates like a cost plus or resale minus,...

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The Cost-Plus Method (CPM): Gross profit margin data expressed as a mark-up of production costs incurred in uncontrolled transactions. OECD GL paragraph 2.45 states that cost plus method begins with the costs incurred by the supplier of property (or services) in a controlled transaction for property transferred or services provided to an associated purchaser. An...

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Most countries, the OECD and the United Nations transfer pricing guidelines have all built in a degree of flexibility into their approaches, allowing other methods to be used in specific cases, provided that they approximate an arm’s length result and are acceptable to all the parties involved – that is acceptable to the tax administration,...

ESG

Materiality and double materiality are two critical concepts in business sustainability reporting, and they play a vital role in ensuring the effectiveness and credibility of sustainability reporting. These concepts determine which sustainability topics are relevant to a business and its stakeholders and the level of detail that should be reported about them. Materiality refers to...