About Graphene Economics™ – African transfer pricing advisors

A specialist African transfer pricing advisory firm built on economic insight, operational understanding and long-term partnership.

Graphene Economics™ is a specialist African transfer pricing advisory firm that helps multinational businesses navigate the complexity of cross-border transactions throughout the continent and beyond.

We work with clients operating across diverse industries and jurisdictions, supporting them with transfer pricing solutions that meet their specific needs.

What differentiates Graphene Economics is our belief that effective transfer pricing cannot be approached as a purely technical compliance exercise. Transfer pricing decisions are shaped by commercial realities, operating models, value chains, economic conditions and the practical challenges of doing business across Africa.

Our approach combines deep transfer pricing expertise with economic analysis and a strong focus on understanding how businesses operate in practice.

Understanding Africa’s business realities

Africa is not a single market. Businesses operating across the continent face vastly different economic, regulatory and operational realities depending on the countries and regions in which they operate.

Transfer pricing policies that may appear straightforward on paper often become more complex when viewed through the lens of differing tax regimes, evolving legislation, foreign exchange constraints, political and economic volatility, infrastructure limitations, data challenges and varying approaches and regulatory interpretations by revenue authorities.

At Graphene Economics, we work with clients to understand these realities and how they affect cross-border transactions, operational decision-making and tax risk.

Our team has experience supporting multinational entities operating across 30 countries in Africa, and we understand the importance of balancing consistency in transfer pricing strategy with the nuances of individual markets.

Map of Africa showing the 30+ countries in which Graphene Economics has provided transfer pricing advisory services
Countries in which GE has worked

Angola, Botswana, Burkina Faso, Cameroon, Comoros, Democratic Republic of Congo, Cote d’Ivoire, Eswatini, Ethiopia, Gabon, Ghana, Guinea, Kenya, Lesotho, Malawi, Mali, Mauritius, Mayotte, Morocco, Mozambique, Namibia, Nigeria, Rwanda, Senegal, Seychelles, Sierra Leone, South Africa, Tanzania, Uganda, Zambia and Zimbabwe

An economic and operational approach to transfer pricing

We believe effective transfer pricing sits at the intersection of tax, economics and business operations.

Transfer pricing decisions are shaped not only by legal and regulatory frameworks, but also by commercial realities, operating models, value chains and the practical complexities of doing business across Africa.

At Graphene Economics, we invest time in understanding how our clients’ businesses operate in practice. This includes engaging with operational teams, finance functions, technical specialists and management teams to build a deeper understanding of how value is created and how businesses function on the ground.

In some cases, this includes spending time on-site with clients to better understand operational processes, technologies and value chains. We believe this practical exposure leads to more commercially grounded transfer pricing solutions and stronger long-term outcomes for clients.

Focused on building long-term client partnerships

We support clients ranging from established multinational groups to growing businesses expanding across Africa and have intentionally built the firm to remain collaborative, responsive and closely connected to our clients’ businesses.

Clients receive senior attention, thoughtful advice and solutions tailored to their business realities. Our experienced specialists invest time in understanding their industries, operational challenges and strategic objectives.


Evolving as transfer pricing changes

Transfer pricing across Africa continues to evolve rapidly, shaped by increased regulatory scrutiny, global tax reform, growing data expectations and heightened audit activity.

We believe transfer pricing is increasingly becoming a strategic business issue rather than a narrow compliance function. As a result, tax teams, finance leaders and boards are placing greater focus on governance, operational visibility and proactive risk management.

Graphene Economics works with clients to navigate this changing environment in a way that is commercially practical, technically robust and aligned with broader business operations.

Our track record and industry contribution

Graphene Economics has been recognised through multiple industry awards, including:

International Tax Review – South African Transfer Pricing Firm of the Year 2021 and 2025
International Tax Review – African Transfer Pricing Firm of the Year 2023
International Tax Review – Tier 1 Transfer Pricing Firm 2019 and 2020

Beyond our client work, we are committed to contributing to the broader transfer pricing profession in Africa through skills development, industry participation and knowledge-sharing.

Founder and director Michael Hewson helped establish the South African Institute of Tax Practitioners (SAIT) transfer pricing training programme and continues to support broader industry initiatives through professional committees and international knowledge-sharing forums.

Graphene Economics also contributes to the industry through annual reports, technical commentary and participation in professional discussions on transfer pricing and cross-border taxation across Africa.

Leadership

Michael Hewson, Founder and Director of Graphene Economics

Michael Hewson

Founder and Director

Michael Hewson has two decades of experience in transfer pricing in Africa. Before founding Graphene Economics, he was a partner at one of the Big 4 in South Africa where he was responsible for supporting the transfer pricing teams across Africa.

He has an MCom in Financial Economics, Honours in Econometrics as well as a Higher Diploma in Tax (Law). Michael has been a guest lecturer on the topic of transfer pricing at the University of Johannesburg, the University of Pretoria as well as the University of Fort Hare. He has contributed to three books and several articles. In addition, he has presented on various aspects of transfer pricing in several countries, including the DRC, Germany, Ghana, Kenya, Mauritius, Mozambique, Netherlands, Rwanda, Tanzania, UAE, UK, and Zimbabwe. His clients include large listed multinational enterprises operating in various different industries.


April Nicholson, Executive Director of Graphene Economics

April Nicholson

Executive Director

April joined Graphene Economics™ in July 2022 and was appointed Executive Director in 2025. She has 14 years’ experience in tax and transfer pricing, including a decade focused exclusively on transfer pricing. Her career began at a Big Four firm in 2011, moving into transfer pricing in 2015, before joining another Big Four team in 2017.

April has led multi-country, multi-team documentation projects for multinational groups in industries ranging from FMCG, mining, and commodity trading to financial services, fintech, and telecommunications. Her expertise spans compliance, planning, model design (including financial modelling and data analytics), Pillar Two safe harbour analysis, and Country-by-Country reporting. She has also assisted clients in managing transfer pricing disputes and queries with revenue authorities across Africa.

April holds a master’s degree in taxation from the University of Pretoria, is a Chartered Accountant (CA(SA)), and a Registered Chartered Tax Advisor™ with the South African Institute of Taxation (SAIT).

Our team

Graphene Economics is supported by a growing team of specialists with experience across economics, transfer pricing, taxation and cross-border advisory.

Our team works collaboratively across projects to support clients operating in different industries, jurisdictions and regulatory environments across Africa.

The Graphene Economics team

About our name

Graphene is a material known for its exceptional strength, flexibility and interconnected structure.

When the firm was founded, the name reflected our belief that effective transfer pricing requires interconnected thinking across economics, business operations, taxation and strategy.

While Graphene Economics has evolved significantly since, that underlying philosophy remains central to how we approach our work today.

Your African transfer pricing specialist