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The Global Minimum Tax: A New Era for Developing Economies
Analyzing the intersection of OECD Pillar Two and the UN Tax Convention proposals, and how these frameworks reshape the competitive landscape for multinational enterprises in the MENA region.
The Case That Wrote the Rules: Unilever Kenya (2005)
When a tax authority takes a major multinational to court, you expect a battle of complex financial models. But in this landmark case, the dispute boiled down to fundamental functional differences and transfer pricing methodologies.
Read InsightThe Global Minimum Tax: A New Era for Developing Economies
An exhaustively detailed analysis of the GloBE model rules, safe harbors, and the strategic options for developing nations as they restructure tax incentives to preserve investment flows.
Read InsightA New Transfer Pricing Paradigm: An Analytical Reading into Pillar One’s Simplified and Streamlined Approach
An analytical reading of the OECD’s Pillar One Simplified and Streamlined Approach (formerly Amount B), detailing its scope, pricing matrix, and implications for Egypt and developing countries.
Read InsightPermanent Establishment Risks in the Remote Era
How decentralized workforce models are pushing boundaries of physical presence thresholds, and how double tax agreements (DTAs) are adapting to protect corporate assets.
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