# Graphene Economics > > Last updated: 2026-08-15 ## Search - Search URL: `https://grapheneeconomics.com?s={query}` ## Recent Content - [SARS - Draft APA notice for public comment](https://grapheneeconomics.com/technical-article/sars-draft-apa-notice-for-public-comment/): Introduction and background The South African Revenue Service (“SARS”) first released a discussion paper on the proposed Advance Pricing Agreement (“APA”) programme for public comment in November 2020 (“Discussion Paper”), followed by the publication of a high-level model and draft legislation in December 2021. The recent proposed legislation issued in April 2026 now aims to... - [Mozambique expands permanent establishment rules for cross-border services](https://grapheneeconomics.com/technical-article/mozambique-expands-permanent-establishment-rules-for-cross-border-services/): It should be noted that recent amendments to Mozambique’s tax legislation, published in late 2025, may have implications for the determination of a permanent establishment (PE) for certain entities receiving services from foreign related parties. The Mozambican PE rules are primarily codified in Article 5 of the Corporate Income Tax (CIT) Code (Law No. 34/2007,... - [Balancing the books or supplying a service? The VAT reality of year-end price adjustments](https://grapheneeconomics.com/technical-article/balancing-the-books-or-supplying-a-service-the-vat-reality-of-year-end-price-adjustments/): By Koveshni Moodley, Senior Manager AT Graphene Economics® Can a year-end transfer pricing adjustment be treated as consideration for a supply of services and therefore be subject to VAT? That was the question before the Court of Justice of the European Union (CJEU) in Stellantis Portugal S.A. (Case C-603/24), decided on 13 May 2026. The... - [From data governance to operational readiness](https://grapheneeconomics.com/from-data-governance-to-operational-readiness/): How TP is changing and what MNEs need to do about it In a recent two-part Fluid Talk webinar series hosted by fluid and Graphene Economics®, speakers Chris Cochrane (fluid CEO), Michael Hewson (Graphene Economics® founder) and April Nicholson (Graphene Economics® executive director) explored how modern tax scrutiny is exposing a broader business challenge. As... - [African and OECD TP updates: July 2026](https://grapheneeconomics.com/african-and-oecd-tp-updates-july-2026/): A round-up of transfer pricing and related updates from around the African continent and beyond. (Sources: reports issued by organisations, government documents and legislation (where available) or other tax news platforms, such as Orbitax, MNETax, etc.) OECD consults on copper pricing framework The OECD and IGF have launched a consultation on a transfer pricing framework... ## Complete Sitemap For a comprehensive list of all URLs, see: https://grapheneeconomics.com/sitemaps.xml --- *This file is dynamically generated and highlights our most important content.*