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…
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…
Media ReleaseJohannesburg, 19 September 2025: Graphene Economics® has been recognised by the International Tax Review (ITR) as South African Transfer Pricing Firm of the Year for 2025, marking another milestone in the firm’s eight-year journey as a specialist in African transfer pricing advisory and strategy. For Michael Hewson, founder and director of Graphene Economics®, the…
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 and G20 updates GloBE information return (pillar two) – status message XML schema (user guide) The OECD released…
As Donald Trump’s second term seems set to be defined in part by a renewed surge of tariffs and trade protectionism, multinational enterprises (MNEs) face complex questions about supply chains, profit allocations, and the overall structuring of their global value chains. According to Michael Hewson, director at specialist African transfer pricing advisory firm, Graphene Economics®,…
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 updates OECD BEPS Action 14 update – March 2025 On 4 March 2025, the OECD released the latest…
OECD updates OECD: Tax Administration 2024 released This report marks the 12th edition of the OECD’s Tax Administration Series, offering the following: Comparative international data on various aspects of tax systems and their administration in 58 advanced and emerging economies; It serves as a resource for tax administration analysts, helping them understand how tax systems…
2023 winner of the African Transfer Pricing Firm of the Year Graphene Economics® has been announced as the 2023 winner of the African Transfer Pricing Firm of the Year at the ITR EMEA Tax Awards held on 27 September 2023. In 2021, Graphene Economics® won South African Transfer Pricing Firm of the Year, and the…
Introduction of Advanced Pricing Agreements in South Africa By NTEBOGENG MAPALETSEBE The South African National Treasury, in its 2023 draft Taxation Laws Amendment Bill (TLAB), proposed the introduction of an Advanced Pricing Agreement (APA) programme, which seeks to enhance transfer pricing (TP) clarity and certainty for taxpayers. The TLAB outlines the legislative framework for APAs…
Source: reports issued by organizations, government documents and legislation (where available) or other tax news platforms, such as Orbitax, MNETax, etc. ATAF: policy brief on considerations in adopting a domestic minimum top-up tax released The African Tax Administration Forum (ATAF) has released a policy brief “Responding to the Implementation of The Global Minimum Taxation: Policy Considerations”….