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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…

Capital Flight, Safe Havens and Secrecy Jurisdictions

"The terms “safe haven” and “secrecy jurisdiction” are arguably more appropriate than “tax haven” or even “offshore financial center” in discussing capital flight. Florida, for example, is thought to be the main destination for capital flight from …

Strategies for Addressing Capital Flight

"This paper discusses strategies to stem capital flight from African countries. It emphasizes the importance of the distinction between licitly and illicitly acquired capital, and the need to tailor strategies to the specific type of capital flight…

A Price-Based Royalty Tax?

In this paper, the author examined the merits of a price-based royalty, a royalty for which the rate varies with the product price, as a fiscal instrument for taxing extractive industries. The case for a price-based royalty is appealing, In light of…

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’ …

Improving the Performance of Natural Resource Taxation in Developing Countries

This paper focuses on the administrative challenges which is posed to developing countries, as a result of the increasing emphasis in fiscal regimes for natural resource extraction since the Second World War on income-based taxes, including both cor…

Safe Harbour Regimes in Transfer Pricing: An African Perspective

The transfer pricing methods established by the transfer pricing rules and practices of countries (generally modelled after the OECD Transfer Pricing Guidelines) are not only complex to implement, but also fraught with challenges – such as the avail…

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