Transfer Pricing for Africa - roundtable discussion. Transfer Pricing Special Event September 22, 2016

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1 Transfer Pricing for Africa - roundtable discussion Transfer Pricing Special Event September 22, 2016

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3 Session Speakers Michael Fortmann Director, Global Transfer Pricing Services, KPMG in South Africa Peter Kinuthia Director, Global Transfer Pricing Services, KPMG in Kenya Victor Onyenkpa Partner, KPMG in Nigeria Susana Pinto Associate Partner, Global Transfer Pricing Services, KPMG in Portugal & Angola

4 Agenda Topics OECD and BEPS Africa Tax Administration Forum Audit Process Tax Administration Dispute Resolution and Tax Controversy 4

5 OECD and BEPS Country by Country reporting Masterfile and Local file Exchange of Information Interest limitations Permanent Establishment ( PE s ) 5

6 Africa Tax Administration Forum Transfer Pricing Legislation Transfer pricing risk assessment model The lack of comparability data Tax Inspectors without Borders Exchange of Information Lack of Double Taxation Agreements ( DTA s ) 6

7 Logan Wort, executive secretary of Ataf Traditionally, arrangements for exchanging information have been bilateral, based around tax treaties and information exchange agreements. However, the [convention] allows in principle for unilateral, bilateral and multilateral exchange. 7

8 Audit Process Planning Gathering information Determining technical position Advise taxpayer of outcome Issue an assessment if required Deal with objections and appeals as necessary 8

9 Tax Administration Prescription of assessments Relevant information Access to information outside the periods under review Interviews with staff Recording of interviews 9

10 Dispute Resolution and Tax Controversy Alternative Dispute Resolution ( ADR ) Settlement Mutual Agreement Procedures ( MAP ) Litigation 10

11 Points To Leave With Changes in legislation due to BEPS and Penalties Exchange of Information & Tax inspectors without borders Process automation and electronic filing Aggressive Adjustments in TP audits 11

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13 Thank you 13

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