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Tax Base Erosion and Profit Shifting in Africa – Part 2: A Critique of Some Priority OECD Actions from an African Perspective

Three of the highest priority actions were identified in this paper, which have the greatest BEPS impact for African economies. These are: Action 4, which deals with limiting base erosion via interest deductions and other financial payments; Action …

How Kenya has Implemented and Adjusted to the Changes in International Transfer Pricing Regulations: 1920-2016

This paper analyses Kenya’s experience of trying to deal with transfer pricing, and looks at difficulties facing developing and middle-income countries in the application of transfer pricing rules. It discusses the course Kenya has taken in introdu…

Limitations of the BEPS Reforms: Looking Beyond Corporate Taxation for Revenue Gains

"This paper argues that global corporate tax policies have long been dominated by a political consensus among governments of countries at all levels of economic development, to the effect that forces of tax competition render taxation of the cross-b…

The Tax Policy Outlook for Developing Countries: Reflections on International Formulary Apportionment

A retrospective analysis is offered by the author regarding his recently-completed extensive research on the technical feasibility of international formulary apportionment of corporate taxable income, as a replacement for the body of ‘arm’s-length’ …

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