International Transfer Pricing

This is an in-house training paper that reviews the highlights of the Income Tax (Country by Country Reporting) Regulations, 2018 released by the Federal Inland Revenue Service.

Opinion expressed herein by the author does not necessarily in anyway represent the Opinion of OECD, ATAF or the Federal Inland Revenue Service (FIRS). The write up is strictly for information purpose, I therefore make no representation as to the accuracy and completeness of the information contained in this publication. I accept no liability for any loss that may arise from the use of this paper.

􏰨􏰊􏰝􏰅􏰁􏰑􏰃 􏰮􏰄􏰆􏰑􏰆􏰁􏰍 􏰨􏰍􏰄􏰃􏰃􏰓􏰃􏰁􏰂 􏰟􏰨􏰮􏰨􏰥 􏰆􏰋 􏰇􏰁􏰃 􏰇􏰗 􏰂􏰌􏰃 􏰜􏰋􏰑􏰅􏰈 􏰆􏰁􏰋􏰂􏰄􏰐􏰓􏰃􏰁􏰂􏰋 􏰗􏰇􏰄 􏰓􏰆􏰁􏰆􏰓􏰆􏰔􏰆􏰁􏰍 􏰂􏰄􏰅􏰁􏰋􏰗􏰃􏰄 􏰘􏰄􏰆􏰑􏰆􏰁􏰍 􏰊􏰆􏰋􏰘􏰐􏰂􏰃􏰋􏰙 􏰀􏰁 􏰀􏰁􏰊􏰇􏰁􏰃􏰋􏰆􏰅􏰕 􏰂􏰌􏰃 􏰄􏰃􏰍􏰐􏰈􏰅􏰂􏰆􏰇􏰁 􏰇􏰗 􏰨􏰮􏰨 􏰖􏰅􏰋 􏰆􏰁􏰆􏰂􏰆􏰅􏰈􏰈􏰎 􏰅􏰊􏰇􏰘􏰂􏰃􏰊 􏰆􏰁 􏰀􏰁􏰑􏰇􏰓􏰃 􏰚􏰅􏰧 􏰯􏰅􏰖 􏰎􏰃􏰅􏰄 􏰡􏰢􏰢􏰢 􏰅􏰄􏰂 􏰣􏰬􏰟􏰰􏰅􏰥􏰙 􏰯􏰅􏰂􏰃􏰄􏰕 􏰂􏰌􏰃 􏰆􏰓􏰘􏰈􏰃􏰓􏰃􏰁􏰂􏰅􏰂􏰆􏰇􏰁 􏰄􏰃􏰍􏰐􏰈􏰅􏰂􏰆􏰇􏰁 􏰖􏰅􏰋 􏰆􏰋􏰋􏰐􏰃􏰊 􏰂􏰌􏰄􏰇􏰐􏰍􏰌 􏰱􏰆􏰄􏰃􏰑􏰂􏰇􏰄􏰅􏰂􏰃 􏰲􏰃􏰁􏰃􏰄􏰅􏰈 􏰇􏰗 􏰚􏰅􏰧􏰃􏰋 􏰳􏰃􏰍􏰐􏰈􏰅􏰂􏰆􏰇􏰁􏰕 􏰮􏰦􏰳 􏰴􏰇􏰙 􏰵􏰶􏰷􏰮􏰸􏰷􏰡􏰢􏰣􏰢􏰙 􏰹􏰇􏰖􏰃􏰝􏰃􏰄􏰕 􏰊􏰐􏰄􏰆􏰁􏰍 􏰂􏰌􏰅􏰂 􏰘􏰃􏰄􏰆􏰇􏰊 􏰂􏰌􏰃 􏰆􏰓􏰘􏰈􏰃􏰓􏰃􏰁􏰂􏰅􏰂􏰆􏰇􏰁 􏰇􏰗 􏰨􏰮􏰨 􏰆􏰁 􏰀􏰁􏰊􏰇􏰁􏰃􏰋􏰆􏰅 􏰖􏰅􏰋 􏰋􏰂􏰆􏰈􏰈 􏰇􏰁 􏰝􏰃􏰄􏰎 􏰈􏰇􏰖 􏰘􏰄􏰇􏰍􏰄􏰃􏰋􏰋􏰙 􏰀􏰁 􏰡􏰢􏰣􏰺 􏰱􏰆􏰄􏰃􏰑􏰂􏰇􏰄􏰅􏰂􏰃 􏰲􏰃􏰁􏰃􏰄􏰅􏰈 􏰇􏰗 􏰚􏰅􏰧􏰅􏰂􏰆􏰇􏰁 􏰟􏰱􏰲􏰚􏰥 􏰌􏰅􏰋 􏰁􏰇􏰂 􏰑􏰇􏰁􏰑􏰈􏰐􏰊􏰃􏰊 􏰂􏰇 􏰅􏰍􏰄􏰃􏰃 􏰇􏰁 􏰅􏰁􏰎 􏰨􏰮􏰨 􏰐􏰁􏰂􏰆􏰈 􏰂􏰌􏰃 􏰈􏰅􏰋􏰂 􏰄􏰃􏰝􏰆􏰋􏰆􏰇􏰁 􏰇􏰗 􏰨􏰮􏰨 􏰄􏰐􏰈􏰃 􏰂􏰌􏰄􏰇􏰐􏰍􏰌 􏰻􏰆􏰁􏰆􏰋􏰂􏰃􏰄 􏰇􏰗 􏰼􏰆􏰁􏰅􏰁􏰑􏰃 􏰳􏰃􏰍􏰐􏰈􏰅􏰂􏰆􏰇􏰁 􏰴􏰇 􏰤􏰷􏰮􏰻􏰽􏰙􏰢􏰰􏰷􏰡􏰢􏰣􏰺􏰙 􏰚􏰌􏰆􏰋 􏰄􏰃􏰋􏰃􏰅􏰄􏰑􏰌 􏰐􏰂􏰆􏰈􏰆􏰔􏰃􏰋 􏰅 􏰊􏰃􏰋􏰑􏰄􏰆􏰘􏰂􏰆􏰝􏰃 􏰾􏰐􏰅􏰈􏰆􏰂􏰅􏰂􏰆􏰝􏰃 􏰓􏰃􏰂􏰌􏰇􏰊􏰇􏰈􏰇􏰍􏰎 􏰖􏰌􏰃􏰄􏰃 􏰊􏰅􏰂􏰅 􏰆􏰋 􏰑􏰇􏰈􏰈􏰃􏰑􏰂􏰃􏰊 􏰂􏰌􏰄􏰇􏰐􏰍􏰌 􏰅 􏰄􏰃􏰝􏰆􏰃􏰖 􏰇􏰗 􏰂􏰌􏰃 􏰈􏰆􏰂􏰃􏰄􏰅􏰂􏰐􏰄􏰃 􏰅􏰁􏰊 􏰋􏰃􏰓􏰆􏰛􏰋􏰂􏰄􏰐􏰑􏰂􏰐􏰄􏰃􏰊 􏰆􏰁􏰛􏰊􏰃􏰘􏰂􏰌 􏰆􏰁􏰂􏰃􏰄􏰝􏰆􏰃􏰖􏰋 􏰖􏰆􏰂􏰌 􏰞􏰃􏰎 􏰋􏰂􏰅􏰞􏰃􏰌􏰇􏰈􏰊􏰃􏰄􏰋􏰙 􏰚􏰌􏰃 􏰄􏰃􏰋􏰐􏰈􏰂 􏰇􏰗 􏰂􏰌􏰆􏰋 􏰄􏰃􏰋􏰃􏰅􏰄􏰑􏰌 􏰋􏰌􏰇􏰖􏰋 􏰂􏰌􏰅􏰂 􏰂􏰌􏰃 􏰊􏰃􏰝􏰃􏰈􏰇􏰘􏰓􏰃􏰁􏰂 􏰇􏰗 􏰨􏰮􏰨 􏰆􏰓􏰘􏰈􏰃􏰓􏰃􏰁􏰂􏰅􏰂􏰆􏰇􏰁 􏰅􏰗􏰂􏰃􏰄 􏰂􏰌􏰃 􏰆􏰋􏰋􏰐􏰅􏰁􏰑􏰃 􏰇􏰗 􏰻􏰆􏰁􏰆􏰋􏰂􏰃􏰄 􏰇􏰗 􏰼􏰆􏰁􏰅􏰁􏰑􏰃 􏰳􏰃􏰍􏰐􏰈􏰅􏰂􏰆􏰇􏰁 􏰴􏰇 􏰤􏰷􏰮􏰻􏰽􏰙􏰢􏰰􏰷􏰡􏰢􏰣􏰺 􏰌􏰅􏰋 􏰆􏰁􏰑􏰄􏰃􏰅􏰋􏰃􏰊􏰙 􏰪􏰅􏰋􏰃􏰊 􏰇􏰁 􏰋􏰂􏰅􏰂􏰆􏰋􏰂􏰆􏰑􏰋 􏰇􏰗 􏰨􏰮􏰨 􏰆􏰁 􏰀􏰁􏰊􏰇􏰁􏰃􏰋􏰆􏰅 􏰅􏰗􏰂􏰃􏰄 􏰡􏰢􏰣􏰵 􏰂􏰌􏰃􏰄􏰃 􏰖􏰅􏰋 􏰅􏰁 􏰆􏰁􏰑􏰄􏰃􏰅􏰋􏰃 􏰆􏰁 􏰂􏰌􏰃 􏰨􏰮􏰨 􏰋􏰐􏰒􏰓􏰆􏰋􏰋􏰆􏰇􏰁􏰋 􏰅􏰁􏰊 􏰂􏰌􏰃 􏰱􏰲􏰚 􏰌􏰅􏰋 􏰋􏰐􏰑􏰑􏰃􏰋􏰋􏰗􏰐􏰈􏰈􏰎 􏰑􏰇􏰁􏰑􏰈􏰐􏰊􏰃􏰊 􏰋􏰇􏰓􏰃 􏰨􏰮􏰨􏰋􏰙 􏰚􏰌􏰃 􏰈􏰅􏰂􏰃􏰋􏰂 􏰨􏰮􏰨 􏰆􏰓􏰘􏰈􏰃􏰓􏰃􏰁􏰂􏰅􏰂􏰆􏰇􏰁 􏰆􏰁 􏰀􏰁􏰊􏰇􏰁􏰃􏰋􏰆􏰅 􏰌􏰅􏰋 􏰗􏰇􏰈􏰈􏰇􏰖􏰃􏰊 􏰂􏰌􏰃 􏰊􏰆􏰋􏰘􏰐􏰂􏰃 􏰄􏰃􏰋􏰇􏰈􏰐􏰂􏰆􏰇􏰁 􏰍􏰐􏰆􏰊􏰃􏰈􏰆􏰁􏰃􏰋 􏰅􏰋 􏰘􏰄􏰇􏰘􏰇􏰋􏰃􏰊 􏰒􏰎 􏰂􏰌􏰃 􏰿􏰄􏰍􏰅􏰁􏰆􏰔􏰅􏰂􏰆􏰇􏰁 􏰗􏰇􏰄 􏰦􏰑􏰇􏰁􏰇􏰓􏰆􏰑 􏰠􏰇􏰇􏰘􏰃􏰄􏰅􏰂􏰆􏰇􏰁 􏰅􏰁􏰊 􏰱􏰃􏰝􏰃􏰈􏰇􏰘􏰓􏰃􏰁􏰂 􏰟􏰿􏰦􏰠􏰱􏰥 􏰂􏰌􏰄􏰇􏰐􏰍􏰌 􏰪􏰅􏰋􏰃 􏰦􏰄􏰇􏰋􏰆􏰇􏰁 􏰅􏰁􏰊 􏰮􏰄􏰇􏰜􏰂 􏱀􏰌􏰆􏰗􏰂􏰆􏰁􏰍 􏰟􏰪􏰦􏰮􏱀􏰥 􏰘􏰄􏰇􏱁􏰃􏰑􏰂 􏰅􏰋 􏰘􏰄􏰇􏰘􏰇􏰋􏰃􏰊 􏰆􏰁 􏰂􏰌􏰃 􏰨􏰑􏰂􏰆􏰇􏰁 􏰮􏰈􏰅􏰁 􏰣􏱂􏰙 􏰹􏰇􏰖􏰃􏰝􏰃􏰄􏰕 􏰂􏰌􏰃􏰄􏰃 􏰅􏰄􏰃 􏰆􏰋􏰋􏰐􏰃􏰋 􏰘􏰃􏰄􏰂􏰅􏰆􏰁􏰆􏰁􏰍 􏰂􏰇 􏰂􏰌􏰃 􏰆􏰓􏰘􏰈􏰃􏰓􏰃􏰁􏰂􏰅􏰂􏰆􏰇􏰁 􏰇􏰗 􏰨􏰮􏰨 􏰋􏰐􏰑􏰌 􏰅􏰋 􏰂􏰄􏰅􏰁􏰋􏰘􏰅􏰄􏰃􏰁􏰑􏰎 􏰅􏰁􏰊 􏰑􏰃􏰄􏰂􏰅􏰆􏰁􏰂􏰎 􏰄􏰃􏰈􏰅􏰂􏰃􏰊 􏰂􏰇 􏰂􏰌􏰃 􏰨􏰮􏰨 􏰘􏰄􏰇􏰑􏰃􏰋􏰋􏰙 􏰳􏰃􏰋􏰘􏰇􏰁􏰊􏰆􏰁􏰍 􏰂􏰇 􏰂􏰌􏰃􏰋􏰃 􏰆􏰋􏰋􏰐􏰃􏰋 􏰂􏰌􏰃 􏰱􏰲􏰚 􏰌􏰅􏰋 􏰓􏰅􏰊􏰃 􏰋􏰃􏰝􏰃􏰄􏰅􏰈 􏰅􏰂􏰂􏰃􏰓􏰘􏰂􏰋 􏰋􏰐􏰑􏰌 􏰅􏰋􏰕 􏰆􏰓􏰘􏰄􏰇􏰝􏰆􏰁􏰍 􏰌􏰐􏰓􏰅􏰁 􏰄􏰃􏰋􏰇􏰐􏰄􏰑􏰃􏰋 􏰅􏰁􏰊 􏰋􏰂􏰄􏰃􏰁􏰍􏰂􏰌􏰃􏰁􏰆􏰁􏰍 􏰂􏰌􏰃 􏰄􏰃􏰍􏰐􏰈􏰅􏰂􏰇􏰄􏰎􏰙

This is a technical paper presented in an in-house training session sometimes in 2015.

The presentation focused on exploring transfer pricing comparability factors recommended by the OECD TP Guidelines of 2010 and the Nigerian Income Tax (Transfer Pricing) Regulations of 2012

Opinion expressed herein by the author does not necessarily in anyway represent the Opinion of OECD, ATAF or the Federal Inland Revenue Service (FIRS). The write up is strictly for information purpose, I therefore make no representation as to the accuracy and completeness of the information contained in this publication. I accept no liability for any loss that may arise from the use of this paper.

This is a technical paper presented in an in-house technical session on 30th August, 2018.

The paper reviewed the changes introduced into the Nigerian Transfer Pricing landscape by the Gazetting of the Income Tax (Transfer Pricing) Regulations, 2018.

Opinion expressed herein by the author does not necessarily in anyway represent the Opinion of OECD, ATAF or the Federal Inland Revenue Service (FIRS). The write up is strictly for information purpose, I therefore make no representation as to the accuracy and completeness of the information contained in this publication. I accept no liability for any loss that may arise from the use of this paper.

Thesis submitted to the Pontifical Catholic University of Peru, to obtain the title of lawyer. The thesis analyses the use of the OECD transfer pricing guidelines in the application of the Peruvian tax law. For this purpose, an analysis of the historical evolution of the arm's length principle and its application around the world, has been done.

The Organisation for Economic Cooperation and Development (‘OECD’) is currently considering best practice approaches to designing rules to prevent base erosion and profit shifting (‘BEPS’) by multinational enterprises (‘MNEs’). However, the OECD makes a distinction between combating BEPS and reducing distortions between the tax treatment of various methods of financing. Yet, an unequal tax treatment can create distortions, which incentivises tax planning behaviour.
Accordingly, this paper aims to improve the tax design of anti-avoidance rules governing MNEs’ cross-border intercompany deductions by introducing the concept of the tax-induced cross-border funding bias. To date, the literature has focussed on the debt bias, which arises from the distortion in the tax treatment between debt and equity financing. On the other hand, the funding bias also includes licensing and leasing activities in addition to debt and equity financing. This presents a novel contribution to the literature.
This paper examines the conceptual case for why is might be appropriate and feasible to restrict the tax deductibility of cross-border intercompany interest, dividends, royalties and lease payments given their mobility and fungibility. Specifically, it examines whether it is preferable for MNEs to be subject to economic rent taxation, as is attained through reform proposals such as the Allowance for Corporate Equity (‘ACE’), in this context. This presents a novel proposal for taxing cross-border intercompany economic rents which aligns with the main aim of corporate tax harmonisation; namely: to reduce, if not remove, distortions relating to the taxation of cross-border intercompany activities.

[Please note: This article has first appeared in Australian Tax Forum and has been reproduced with permission from the Tax Institute]

Customs valuation and transfer pricing are vital topics in international trade taxation. Both methodologies pursue different objectives in assessing the value of goods traded between related parties. Nonetheless, in pursuit of tax certainty and revenue mobilisation,
there is a growing need for better communication between these two international valuation systems. Therefore, the objective of this article is to bring customs valuation and transfer pricing together by commenting on the latest WCO/TCCV developments, namely case studies 14.1 (TNMM) and 14.2 (RPM) guiding Customs on the use of transfer pricing
documentation to examine the circumstances of the sale in related party transactions. The article also addresses the key elements of transfer pricing documentation and the challenges ahead for both systems.

The Organisation for Economic Cooperation and Development (‘OECD’) is currently considering best practice approaches to designing rules to prevent base erosion and profit shifting (‘BEPS’) by multinational enterprises (‘MNEs’). However, the OECD makes a distinction between combating BEPS and reducing distortions between the tax treatment of various methods of financing. Yet, an unequal tax treatment can create distortions, which incentivises tax planning behaviour. Accordingly, this paper aims to improve the tax design of anti-avoidance rules governing MNEs’ cross-border intercompany deductions by introducing the concept of the tax-induced cross-border funding bias. To date, the literature has focussed on the debt bias, which arises from the distortion in the tax treatment between debt and equity financing. On the other hand, the funding bias also includes licensing and leasing activities in addition to debt and equity financing. This presents a novel contribution to the literature....

The advent of the digital age has been the key driving influence of all human activities in the 21st century and birthed the digital revolution. The digital revolution has taken place. It has given rise to a digital economy that challenges our concept of value creation. The focus of this paper would be on Intangibles, which is known as Digital Goods, and the Taxation Challenges.

Article on proposed Diverted Profits Tax Regime in the United Kingdom.

The article makes a point that DPT is unilateral treaty override mechanism.

The article throws light how new regime is ambiguously worded and how it can negatively impact genuine business arrangements.

International taxation architecture is set for complete overhaul. The Digitalization of economies and resulting revenue losses due to inability of the jurisdictions to tax the cross-border transactions has made it imperative to quickly fix the international taxation system.
The ongoing work on taxation digital economy has so far has progressed well but the complexity in design of the system is enormous. The availability of data continues to be a challenge in designing the system.  Recent OECD estimate is new system design without safe harbor could lead to additional CIT of USD100 billion or around 4% of the global CIT. This additional gain is not as optimistic as was the case made in 2014. After taking safe harbor taken into account, it is estimated that it may be even less. It will be better to develop a robust and credible system than to develop an imperfect system with little gains.
From the recent economic analysis presented by OECD, it is seen that the revenue gain from pillar 1 is very low in comparisons to pillar 2. This paper suggests the following as a possible solution-
a. Under pillar 2 let countries agree to a minimum tax in a range say 17.5-20%. Within the band countries can choose to select the tax rates. This small band will not leave much leverage to use other intermediate jurisdictions and will place all jurisdiction on the same footings in terms of tax rates. This can be achieved through Multilateral convention and open to all IF as well as non -IF countries. For non- signatories, affected countries may put equalization tax, which will be gap of their tax rates and tax rates in non-signatory country to convention. This will be very simple to administer without no complexity. The small band of tax rates will ensure that cost of tax planning does not justify the shifting of profit from one jurisdiction to other. This will provide self-check as well sovereignty to country to fix a rate of choice in the given band.
b. For pillar 1, the proposed solution is not yielding much revenue gain and same will further go down with adoption of safe harbor as proposed by US. In this context, the proposal of G24 countries as discussed in the paper using apportionment of the profit may be solution by providing an enabling clause in the suggested multilateral convention.
It will pay in long term to keep design simple and easily implementable by the countries. In the process of development of a new system, governance architecture in OECD IF has emerged a critical issue. OECD has done its best to accommodate and include 130 plus countries under this framework. OECD governance framework was meant for limited and similarly placed economies as per constitution. OECD governance framework has been expanded to deal with new reality and OECD has done excellent job. However, to make the process truly inclusive there is a need for a Global Tax Organization (GTO) on the lines of existing International organizations like IMF/WBG, WCO, WTO etc. to make the process truly inclusive, democratic and robust in governance. Some of the developing countries in G20 in forthcoming G20 Summit could explore to host such GTO in collaboration with OECD. Such a critical topic of International taxation cannot be left to an adhoc structure as this will require a continuous and long-term approach in view of the emerging business models and challenges from disruptive technologies in years to come.
The need for a robust global taxation architecture is as critical as it was for development organization after the second World War. G20 with its political clout is well placed for this historic reform and developing countries in G20 have to take lead.
                                         


 

The article provides summary and analysis of the OECD's discussion draft released on 4 July 2016 on revised guidance on profit split method ('PSM).

The authors analyse the two approaches of the profit split methods given by OECD discussion draft i.e. PSM involving split of actual profits and PSM involving split of anticipated profits and criteria for selecting one of these approaches and explore situations in which PSM is to be selected as most appropriate method.

The article further discusses the guidance given by discussion draft in context of applying PSM to group synergies and using value chain analysis as a tool for applying PSM.

The authors have also presented their views on the guidance with relevant examples and have observed that, new guidance on PSM has introduced objectivity in respect of application of PSM as transfer pricing method, while also attempted to codify certain aspects of its application which may introduce rigidity in selection of this method as most appropriate method.

From time immemorial, businesses have always been involved in Price Wars because of competition which has always been a consumer win it all affairs. The purpose of this presentation is to key into the EFG360 PROJECT. Businesses from the archive of history have never come out the same in a price war which we will get to see during the course of this presentation. For instance, Creating low price appeal is often the goal, but the result of one retaliatory price slashing after another is often a precipitous decline in industry profits. Look at the airline price wars of 1992. When American Airlines, Northwest Airlines, and other U.S. carriers went toe-to-toe in matching and exceeding one another’s reduced fares, the result was record volumes of air travel and record losses. Some estimates suggest that the overall losses suffered by the industry that year exceed the combined profits for the entire industry from its inception.

This article provides an overview of the Transfer Pricing Regime in Nigeria. It gives a brief on the Income Tax (Transfer Pricing) Regulation No. 1, 2012 (TPR) and provides insights into questions like Transactions covered by the TPR, who should file a TP Return, who is a connected Person under the Nigerian Transfer Pricing Regulation, what constitutes a TP Return, effective date for compliance with the TP Regulation, where to submit TP returns and Implication of the TP Regime for businesses in Nigeria.

The article is meant for information purposes only. It does not in any way represent the position of the FIRS. We therefore make no representation as to the accuracy and completeness of the information contained in this publication. We accept no liability for any loss that may arise from the use of the article.

This is first international concept paper on this subject and applications of Blockchain/DLT to Multinational Transfer Pricing discussed below is futuristic in nature. The DLT/Blockchain as a technology is at very nascent stage and it may take few years before the applications discussed below are brought into practise

Intercompany financing transactions are becoming increasingly important to multinational enterprises (MNEs) as they expand internationally. Corporate treasurers of MNEs have many responsibilities, including the management of international capital structure and cost of capital, the financing of cross-border acquisitions, foreign direct investment, international capital budgeting and cash management, management of foreign exchange and transactional risk, and port-folio and investment management.This article focuses on a corporate function, transfer pricing, that is potentially relevant to each of these activities. Whenever a payment crosses borders in a treasury context—whether to provide a loan, purchase a receivable, provide a guarantee, sweep cash, factor a receivable, provide a hedge or insurance product—a transfer pricing issue is present. Transfer pricing is often viewed as a taxation issue and thus the responsibility of the corporate tax department. This article challenges that view, and makes the case that an integrated, multi-functional approach to MNE treasury planning in the context of transfer pricing can be an important component in improving the efficiency of cross-border financial management. The paper uses conceptual and empirical information as well as numerical examples to illustrate relevant tax and transfer pricing concepts for policy planners and others responsible for MNE treasury and tax planning.

Fiscal sustainability has eluded most resource-rich African countries, as they have not used resource rents for social and economic development, and exhibit unsustainable debts, poverty and corruption (the "resource curse"). This article concludes that the "resource curse" is attributable to economic, legal, political and socio-cultural factors. Fiscal sustainability has eluded many natural resource-rich developing countries, such as Angola and Nigeria, which are experiencing regressive growth and significant poverty despite the vast resource rents available. These profoundly negative effects have given rise to significant debate as to how oil-rich Uganda can evade the "resource curse" and realize fiscal sustainability. There is a fear that Uganda's previous economic gains [1] could be reversed by oil exploitation. The World Bank (2011) [2] notes the challenges that could undermine Uganda's future development, including sustaining macroeconomic stability, a rapidly growing population, the discovery of oil reserves and increased corruption. Stevens (2003) [3] posits that countries with very large oil reserves have high public spending positions due to expectations of oil windfalls, which is a behaviour that compromises fiscal sustainability, as oil is nonrenewable.

Foreign Direct Investment (FDI) is critical for developing countries as source for financing as well as for accessing technological innovation happening around the World. Countries have been competing through tax rates, special economic zones to attract the FDI. Over the years many countries have carried reforms and achieved high ranking in the Doing business report. Countries and political leadership have pitched the reforms as ‘The’ tools for FDI.
On the basis of five-year doing business data of top ten performing economies, it has been found that these reforms and high ranking and top performing countries are not necessarily attracting FDI and through analysis no strong correlation could be established. However, there is evidence to suggest that continuous reforms and timed appropriately could be factor in maintaining  as well as enhancing the FDI in a country.

The article deals with the multi billion transfer pricing disputes in India in respect of taxation of share capital !  The Vodafone Judgment conclusion & my article (written before pronouncement) are on same page.

New Europe is leading EU weekly newspaper based in Brussels predominantly read by 10000 European Officials, political scientists, business heads and common people among other across Europe

Nigeria's principal corporate tax legislation, the Companies Income Tax Act 1961, stipulates as a basis for the taxation of a nonresident company deriving income in Nigeria, what it terms a "single contract." This, according to the statute, entails a contract that embodies the activities of surveys, deliveries, installations or construction (common features of what is in common parlance termed a "turnkey project"). A major challenge with the application of the provision lies in the comprehension of the pivotal term, "single contract." A diversity of views on the import of the term paints a telling picture of ambiguity and underlies the complication of its applicability. A recent decision of the Nigerian Court of Appeal provided some much-needed judicial perspective on the point. The Court in the said case advanced a line of reasoning which almost certainly guarantees tax liability in Nigeria for a nonresident company participating in a Nigerian turnkey project regardless, it seems, of how the relevant contract is structured or performed-an apparent leaning towards an anti-avoidance objective of statutory interpretation. This paper, in search of clarity, examines the decision of the Court in Saipem Contracting Nig. Ltd & 2 Ors. v Federal Inland Revenue Service & 2 Ors. in view of the language of the Act, case law and other perspectives both at home and abroad.

Alignment between an entity’s strategic business objectives and its information systems (ISs) has recently received research attention. Currently, small and medium-sized entities (SMEs) still face the challenge of successfully aligning their strategic business objectives with their ISs. Various small generic accounting software packages are available for purchase by SMEs. These accounting packages all have functionalities that enable SMEs to keep proper accounting records. However, due to their generic nature, these accounting packages do not always have sufficient functionalities to drive the SMEs’ strategic business objectives, resulting in IS misalignment. Not selecting the correct accounting software package will result in the accounting software not addressing the strategic business needs of the
SME.

The purpose of this study is to review and discuss the challenges faced by SMEs when selecting generic accounting packages and to develop a mapping between strategic business objectives commonly found within SMEs and software package functionalities that SMEs can refer to during the selection and implementation of new accounting software
packages. This is accomplished on a non-empirical basis through a review of pertinent literature.

In order for a SME to select the correct accounting software package, it is important that it invest time and effort in considering the software functionalities provided by the software package and map it against its strategic business imperatives to prevent failure of the package.

ABSTRACT

International trade pricing is defined by the concept of International Parity Price or (IPP), “The price that a purchaser pays or can expect to pay for imported goods; thus the (c.i.f.) import price plus tariff plus transport cost to the purchaser's location. This and the export parity price together define a range of the possible equilibrium prices for equivalent domestically produced goods”.
The UN World Food Program definition: “The import parity price (IPP) is the price at the border of a good that is imported, which includes international transport costs and tariffs”.

The USAID Market and Trade Glossary definition: "Import parity price (IPP) – is the monetary value of a unit of product bought from a foreign country, valued at a geographic location of interest in the importing country".
These definitions are used in International trade and are sometimes referred to as the International Benchmark which describes the same thing (IPP):

• If the goods don’t require production inputs, such as water, a mineral or farming, obtained at local prices before import/export the domestic price of locally produced goods must remain the same and may not be influenced by the IPP.
• If a quantity of imported goods is less than the quantity available locally, the locally produced goods must continue to be sold at their local prices and the cost of the imported quantity covered by its value being added to the quantity cost of the goods being sold in the domestic market.
• If the imported quantity is more than the quantity available locally, the cost of the imported quantity is covered by its value being added to the quantity cost of the goods being sold in the domestic market.
• If there are regional divisions or markets within the country, the above considerations usually apply only to the region or market that imports the goods; and the domestic selling price in the regions or markets that do not import the goods is not affected by the IPP.
• The IPP or International Benchmark Price is 'set' periodically- usually monthly- by the country that exports the largest volume of a commodity. Other exporting countries may set their own export prices or use the IPP, whichever is advantageous to them.

The selling price of imported goods is the sum of its cost, tariffs, freight, insurance and other charges including profits (CIF). The IPP is often used by sellers instead of the import price when the IPP is higher and provides a profit advantage to the seller. The price of imported goods or the IPP is applied to locally produced goods of the same type whose local-production price is lower than the imported goods unless the quantity that is imported is vastly more than the quantity that is locally produced.
Import Parity Price has no economic or trade validity. It is considered a variation of Purchasing Power Parity, which is an entirely different concept that is economically accepted. The IPP is a recent concept of globalization by commercial businesses that enables them to profit from imports and/or exports. The IPP cannot therefore be a policy to determine the local selling price of a locally produced commodity. Developed countries do not use the IPP to determine local selling prices; instead, prices are determined by the local production cost.

Firstly, this assignment outlines the main concepts stressed by BEPS Action 4. Secondly, we highlight some of the major practical consequences on companies and on the so called “state of the art”. In this regard, we conclude that Action 4 challenges one the cornerstone principles that sustain corporate finance theory: the principle preconized by Modigliani–Miller (II) that a company leveraged is better than a company unleveraged (macro-view), alongside with other spillover-effects (micro-view).

This lengthy submission includes recommendations in a number of international tax areas for regulation changes, improvements, and modernization. It includes for a number of areas suggested regulatory language that could be considered.

Much of the submission concerns sourcing and effectively connected income rules. It also covers the existence of unanticipated partnerships among an MNC's group members that conduct joint business activities. Regarding subpart F, it makes suggestions concerning the manufacturing branch rule. Finally, it includes suggestions regarding the manner in which tax treaties should or should not apply to certain hybrid entities and how cost sharing agreements should be administered under Rev Proc 2015-41.