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Expert Analysis

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Transfer Pricing
Multinationals face rising TP scrutiny as global rules diverge. As Daniel Moalusi argues, strong, consistent documentation is now essential to minimise audit risk and protect tax positions
February 26, 2026
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  • Tax is one of the 11 indicators used by the World Bank to assess the ease of doing business for small and medium enterprises (SMEs) in more than 180 countries. An independent panel created by World Bank President Jim Yong Kim released a report last month reviewing these indicators. Jeffrey Owens, director of the WU Global Tax Policy Centre at the Institute for Austrian and International Tax Law, examines the panel’s conclusions regarding the tax indicators.
  • Mariano Giralt and Conor Begley of BNY Mellon explain why developing markets and expanding regulation, not to mention investor scrutiny, mean that investment managers and fund administrators cannot ignore tax when deciding on their distribution strategy.
  • An understanding of the domestic limitation of benefit provisions applicable to the tax treaties entered into by some African jurisdictions is essential if transaction pitfalls are to be avoided, warn Leon Steenkamp and Stephen Hales, of Ernst & Young.

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