Transfer pricing Thin capitalisation International tax ... · ICAZ Transfer pricing Thin capitalisation International tax planning Presented by : Max Presented by : Max Ngorima Ngorima

ICAZICAZICAZICAZTransfer pricingTransfer pricing

Thin capitalisationThin capitalisation

International tax planningInternational tax planningPresented by : Max Presented by : Max NgorimaNgorima --March 2012March 2012

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1 Transfer Pricing at a glance

1.1 What is transfer pricing?

1.2 What is the arm’s length principle?

1.3 Avoiding tax disputes

2 Transfer pricing methods

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2 Transfer pricing methods

2.1 Overview

2.2 Traditional Transaction Methods

2.3 Profit orientated Methods

2.4 Other Methods

2.5 Overview Methods used by transaction type

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3 Thin capitalisation

3.1 Definitions

3.2 Example

4 International tax planning


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4 International tax planning

4.1 Restructuring

4.2 Shifting of functions

5 Zimbabwe transfer pricing legislation

6 Conclusion

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1.TRANSFER PRICING1.TRANSFER PRICING


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WHAT IS TRANSFER PRICING?


1 Transfer pricing at a glance1 Transfer pricing at a glance1.1 What is transfer pricing?1.1 What is transfer pricing?

Definition

• Transfer pricing is the pricing of intercompany transactions that

take place between affiliated enterprises or between headquarter

and branch. The transfer pricing process determines the amount

of income that each party earns.


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of income that each party earns.



Government Definition

• Transfer pricing is the manipulation of prices between related

subsidiaries when they transfer goods and services between

themselves across national borders, inorder to reduce their profits

in a higher tax jurisdiction.


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in a higher tax jurisdiction.



Definition

• Involves the pricing of goods or services outside normal

commercial parameters so as to gain some tax advantages


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commercial parameters so as to gain some tax advantages



What are the aims of transfer regulation pricing ?

Transfer pricing provisions aim to adjust prices in order to reflect an

arm’s length price which would have applied had the transaction

been concluded on normal commercial grounds between unrelated

parties.


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parties.


TRANSFER PRICINGTRANSFER PRICING


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WHAT IS THE ARM’S LENGTH PRINCIPLE?


1 Transfer pricing at a glance1 Transfer pricing at a glance1.2 What is the arm’s length principle?1.2 What is the arm’s length principle?

Definition

The arm’s length principle requires that compensation for any intercompany

transaction shall conform to the level that would have applied had the

transaction taken place between unrelated parties, all other factors

remaining the same.

(Definition: Art. 9 para. 1 Organisation of economic development {OECD}-MC:


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(Definition: Art. 9 para. 1 Organisation of economic development {OECD}-MC:

para. 1.6 OECD-Guidelines)

Important factors influencing the determination of arm’s length compensation

• Type of transaction

• Economic circumstances surrounding the transaction


1 Transfer pricing at a glance1 Transfer pricing at a glance1.2 What is the arm’s length principle?1.2 What is the arm’s length principle?

Problems related with the arm’s length principle

• lack of agreement as to what constitutes an arm’s length transaction

• lack of comparable transactions (little or no evidence of what conditions

would have been established by independent enterprises)

• information difficult to obtain for reasons of confidentiality


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• accessible information may be incomplete or difficult to interpret


1 Transfer pricing at a glance1 Transfer pricing at a glance1.3 Avoiding tax disputes1.3 Avoiding tax disputes

Advance Pricing Arrangement (APA)

Definition

• An arrangement that determines, in advance of controlled transactions,

an appropriate set of criteria (e.g. Method, comparables and appropriate

adjustments thereto, critical assumptions as to future events) for the

determination of the transactions between related entities over a fixed


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determination of the transactions between related entities over a fixed

period of time.

An advance pricing arrangement may be unilateral involving one tax

administration and a taxpayer or multilateral involving the agreement of

two or more tax administrations.

Goal

• Resolving tax disputes before they start and creating an assurance in

advance for taxpayers that a consistant approach will be taken by the

governments involved in a cross border transaction.


TRANSFER PRICINGTRANSFER PRICING


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TRANSFER PRICING METHODS


2 Transfer Pricing Methods2 Transfer Pricing Methods2.1 Overview2.1 Overview

Traditional transaction methods

• Comparable Uncontrolled Price Method (CUP)

• Resale Price Method (RPM)

• Cost-Plus Method


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Profit Oriented Methods

• Transactional Net Margin Method (TNM)

• Comparable Profits Method (CPM)

• Profit Split Method

Other methods


2 Transfer Pricing Methods2 Transfer Pricing Methods2.2 Traditional transaction methods2.2 Traditional transaction methods


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TRADITIONAL TRANSACTION METHODS



Comparable Uncontrolled Price Method

Comparison of the price for goods or services transferred in a controlled

trans-action with the price charged for goods or services transferred in a

comparable uncontrolled transaction in comparable circumstances.

External price Internal price


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External price Internal pricecomparison comparison

x

y y

Group Group

P

S

P

S



Example: Comparable Uncontrolled Price Method (CUP)

• An independent enterprise sells branded suits (Hugo Boss) to P & C.

P & C produces suits (“no name” suits) of a similar quality and quantity

and sells them to affiliated enterprises. The application of CUP is not

possible, as the suits are not of the same type.


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• A captive finance company grants a loan of Us $10 m at the rate of 6.5%

to an associated company. Banks would grant the loan at a rate of 5.6 to

6%. The application of CUP is possible. A rate of 6% is acceptable at

most as it is within the range of acceptable rates.



A cup may arise where:

• The taxpayer or another member of the group sells the particular

product, in similar quantities and under similar terms to arm’s length

parties in similar markets (an internal comparative);

• An arm’s length party sells the particular product, in similar quantities

and under similar terms to another arm’s length party in similar markets


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and under similar terms to another arm’s length party in similar markets

(an external comparable);

• The taxpayer or another member of the group buys the particular

product, in similar quantities and under similar terms from arm’s length

parties in similar markets (an internal comparable); or

• An arm’s length party buys the particular product, in similar quantities

and under similar terms from another arm’s length party in similar

markets (an external comparable).



Traditional transaction methods in brief

TP - method Determination of TP Application areas

ComparableUncontrolledPrice method

• Comparison with price stipulated in a comparable uncontrolled transaction in comparable circumstances

• External/internal price

Principle:• Standardised and marketable

goods and servicesExamples:• Goods quoted on the stock


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• External/internal price comparison

• Direct/indirect price comparison

• Goods quoted on the stock exchange

• Goods for which prices customary in a trade are available

• Commercial services• Loans• Licence agreements



Resale Price Method (RPM)

A transfer pricing method based on the price at which a product that has been

purchased from an associated enterprise is resold to an independent

enterprise. The resale price is reduced by the resale price margin. What is

left after subtracting the resale price margin can be regarded, after

adjustment for other costs associated with the purchase of the product (e.g.


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Custom duties), as an arm’s length price of the original transfer of property

between the associated enterprises.



Examples: Resale Price method

• I, an Italian company, manufactures and sells sports shirts. Subsidiaries

in Germany, France, and the UK serve as distributors. Independent

comparable distributors of sports shirts earn gross margins of 25%. The

independent distributors also design the shirts, whereas the related


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independent distributors also design the shirts, whereas the related

party distributors do not. The typical charge for designing shirts is 3% on

sales. Based on this information, the comparable resale price margin has

to be adjusted for the design function. Therefore, the gross margin to

be earned by the related party distributors is reduced from 25 to 22% to

account for the absence of a design function.



Examples: Resale Price Method

• Two distributors sell the same product in the same market under the

same brand name. Distributor A offers a warranty: distributor B offers

non. Distributor A is not including the warranty as part of a pricing

strategy and so sells its product at a higher price resulting in a higher


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strategy and so sells its product at a higher price resulting in a higher

gross profit margin (if the costs of servicing the warranty are not taken

into account) than that of Distributor B, which sells at a lower price.

The two margins are not comparable until an adjustment is made to

account for that difference.


2 Resale price method2 Resale price method2.2 Traditional transaction methods2.2 Traditional transaction methods



Resale PriceMethod

• Base: resale price at which the associated enterprise sells the product to an independent enterprise

Principle:• Suited especially for

companies that sells goods to affiliated companies


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independent enterprise• Reduction by a resale price

margin usual in the market which shall cover costs resulting from the functions and risks adopted and an appropriate profit mark-up

to affiliated companies which resell them

Example:• Distribution companies



Cost Plus Method

A transfer pricing method using the costs incurred by the supplier of

property (or services) in a controlled transaction. An appropriate cost

plus mark up is added to this cost, to make an appropriate profit in light

of the functions performed (taking into account assets used and risks

assumed) and the market conditions. What is arrived at after adding the


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cost plus mark up to the above costs may be regarded as an arm’s length

price of the original controlled transaction.



Cost Plus Method

Costs (direct and indirect) 100,000Є

+ appropriate cost plus mark up (often 5-10%) 10,000Є

= transfer price 110,000Є


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• Basically actual costs, otherwise predetermined target costs or the like have to be agreed upon

• Costs plus mark up must be customarily (internally) or customary in a line of business (externally)

Main area application

• Production enterprises• Contract manufacturing• services



Example: Cost Plus Method

• U, a UK specialist glass manufacturer conducts all of its research and

development and manufacturing activities in the UK, U’s Irish affiliate

processes the glass. As the Irish affiliate performs limited manufacturing

activities and engages in no production scheduling, materials,

purchasing, or technical service it can be regarded as a contract


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manufacturer. The affiliate is also performing manufacturing services

for unrelated companies; thus comparable information will be available

from these transactions. The mark up the Irish affiliate earns on services

provided to unrelated companies can be used to apply a cost plus

method to related party transaction.





Cost plusmethod

• Base: costs in a controlled transaction

• Addition of an appropriate cost plus mark up

Principle:• Suited for transactions where

no market prices are available

Example:


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Example:• Goods and services being

specific to the group• Services provided within a

group• Semi-finished products• Long-term supply contracts


2 Transfer Pricing Methods2 Transfer Pricing Methods2.2 Profit oriented methods2.2 Profit oriented methods

Profit orientated methods


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2 Transfer Pricing Methods2 Transfer Pricing Methods2.3 Profit orientated methods2.3 Profit orientated methods

Principle of subsidiarity (all profit orientated transfer pricing methods)

• Traditional transaction methods take priority over profit orientated

transfer pricing methods (para 2.49 and 3.1 OECD-Guidelines)

• Preferred application of profit orientated transfer pricing methods in

the US.


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the US.

• Increasing application of profit orientated transfer pricing methods in

other countries (e.g UK and Japan)



Transactional Net Margin Method (TNMM)

The transactional net margin method examines the net profit margin relative

to an appropriate base (e.g. Costs, sales assets) that a taxpayer realises from

a controlled transaction (or a coherant group of transactions)

Procedure

• Determination of the net profit margin in a controlled transaction


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• Determination of the net profit margin in a controlled transaction

• Determination of the net profit margin in a comparable uncontrolled

transaction

• Functional analysis of comparable transactions

Problem

Normally no data from external transactions available; thus TNMM is generally

only applicable in case of internal price comparisons



Comparable profits method (CPM)

The comparable profits method evaluates an arm’s length nature of a controlled transaction by using objective measures of profitability derived from uncontrolled taxpayers engaging in similar business activities under similar circumstances.

Procedure


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Procedure

• determination of comparable businesses

• determination of financial ratios (e.g. profit margin, return on investment) of comparable businesses

• determination of the financial ratios of the affiliate and comparison with the respective financial ratios of the comparable businesses

• if the financial ratios of the affiliate are within the range of the comparables the transfer price is regarded as appropriate



Example: Comparable profits method (CPM)

• Average reported operating profit within the range?

• Average reported operating profit (20,000) of S withing the interquartile

• Range ranging from $19,760 to $34,840.


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• Transfer prices comply with arm’s length principle.



Profit split method

The transactional profit split method identifies the combined profit to be split for the associated enterprises from a controlled transaction (or a coherent group of transactions) and the splits those profits between the associated enterprises based upon an economically valid basis that approximates the division of profits that would have been anticipated and reflected in an agreement made at arm’s length.

Forms of profit split


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Forms of profit split

• Contribution analysis (para3.16 - Residual analysis (para 3.19 OECD-Guidelines) OECD-Guidelines)

• determination of the combined - determination of the profit accounting profits for precious intangible property

• profit split relative to the functions - split of residual profit relative to theand risks being assumed functions and being assumed

THIN CAPITALISATIONTHIN CAPITALISATION

BDO Kudenga &


11 Thin Thin capitalisationcapitalisation1.1 What is thin 1.1 What is thin capitalisationcapitalisation??

Thin Capitalisation

Relates to the funding of a business with a disproportionate degree of

debt in relation to equity so as to provide the foreign investor the

benefit of having the interest income derived there from exempt

whilst at the same time enjoying the benefit of tax advantage


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whilst at the same time enjoying the benefit of tax advantage

relating to the deductibility of interest payment of debt.



Thin Capitalisation

Section 16 (1) q)

• any expenditure incurred by a local branch or subsidiary of a

foreign company, or by a local company or subsidiary of a local


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foreign company, or by a local company or subsidiary of a local

company, in servicing any debt or debts contracted in connection

with the production of income to the extent that such debt or

debts cause the person to exceed a debt to equity ration 3:1.


1 Thin 1 Thin capitalisationcapitalisation1.1 Example1.1 Example

Thin Capitalisation

Example:-

D Ltd is the Zimbabwe subsidiary of A Ltd, a company listed in India.

During the year ended 31st December 2010, D Ltd borrowed $2 million


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During the year ended 31 December 2010, D Ltd borrowed $2 million

dollars from A Ltd to fund capital expenditure. Interest of $200 000

was paid on the loan. The average debt to equity ration of D Ltd

was 4:1.


1 THIN CAPITALISATION1 THIN CAPITALISATION1.1 Example1.1 Example

Thin Capitalisation

Interest paid D Ltd $200 000

Allowable (3:1) ¾ of 200 000 ($150 000)

Disallowed interest $50 000


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$50 000 deemed to be a dividend subject to 15% withholding tax of

$7,500.


TAX PLANNINGTAX PLANNING


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40

INCOME TAX (restructuring)INCOME TAX (restructuring)

• Where ever possible, reconstruct companies under common control so that profits of successful companies can be offset against those with tax losses.

• There is an unfortunate tendency to form

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• There is an unfortunate tendency to form new companies every time a new activity is embarked upon:- establishing a division can be just as tax effective and efficient.


3 Shifting of functions/change of functions3 Shifting of functions/change of functions3.1 Definitions3.1 Definitions

Shifting of functions

• Transfer of operational functions (together with risks) from one affiliated enterprise to another affiliated enterprise or branch, for example:

- production

- distribution

- services


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- financial services

- research and development

Change of functions

• Functions (together with risks) are reduced to reduce the profits generated (producer –contract manufacturer) or increased to increase the profits generated (contract manufacturer-producer)


3 Shifting of functions/change of functions3 Shifting of functions/change of functions3.2 Reasons for shifting of functions3.2 Reasons for shifting of functions

• Strengthening of the position of the company in competition

• Cost savings resulting from advantages of location

• Development of new markets

• Laws being more liberal with respect to research


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• Avoidance or reduction of customs duties/restrictions on trade

• Optimization of transfer pricing with respect to the value chain

• Reduction of the tax burden of the group


3 Shifting of functions/change of functions3 Shifting of functions/change of functions3.3 Problems connected with the shifting of functions3.3 Problems connected with the shifting of functions

• Qualification and mentality of the employees

• Lack of quality

• Costs connected with transport

• Delivery periods

• Protection of intangible property


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• Protection of intangible property

• Corruption

• Political instability

• Taxation of capital gains from the shifting of functions


3 Shifting of functions/change of functions3 Shifting of functions/change of functions3.4 Taxation3.4 Taxation

• Taxation of the shifting of functions- Transfer of single tangible or intangible assets from one affiliated

enterprise to another. The transfer price has to be consistent with the arm’s length principle- The transfer of assets results in a taxation of hidden reserve

- Transfer of a business or an operating unit- determination of the company value (arm’s length price does not correspond with the sum of the values of the assets of the business of the operating unit)


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• Taxation of functions after the shifting of functions

- Application of transfer pricing methods to cross-border business

connections

- Consideration of the value –added contribution

Zimbabwe transfer legislation

BDO Tax & Advisory Services (Pvt) LtdBDO Tax & Advisory Services (Pvt) LtdBDO Tax & Advisory Services (Pvt) LtdBDO Tax & Advisory Services (Pvt) LtdBDO Tax & Advisory Services (Pvt) Ltd1 TRANSFER PRICING AND INCOME TAX1 TRANSFER PRICING AND INCOME TAX

• This presentation takes a look at the legislation in relation to transfer pricing and income tax at both the national and international level.

1.1 National

a) The Legislation: The relevant legislation, as far as non-external

trading is concerned, is contained in sections 23 and paragraph 8 A

of the Fourth Schedule and paragraph 8 of the Fifth Schedule of the


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Income Tax Act.


b) Section 23 (1) deals with sales of any property, movable or immovable, at

less than fair market price. In determining the taxable income or

assessed loss of any person trading in Zimbabwe, the Commissioner

may..


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(i) increase the seller’s price to fair market price (without increasing the price paid by the purchaser);

(ii) decrease the purchaser’s price to fair market value (without decreasing the price received by the seller)


1.2c) The local case of Elite Wholesale (Rhodesia) (Pvt) Ltd v COT (1955) (SR),

20 SATC 33, dealt with similar legislation and the following aids to interpreting section 23 (1) come from this decision...

• The Commissioner’s power is discretionary not mandatory • The power cannot be used to penalise perfectly innocent transactions or

where the transaction is not tainted with dishonesty• The power cannot be invoked where a trader honestly sells to the poor

and charitable institutions or to obtain cash to meet pressing liabilities


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The power cannot be invoked where a trader honestly sells to the poor and charitable institutions or to obtain cash to meet pressing liabilities

• The power is there to protect the public revenue to tax what ought to be taxed

• The power should be applied where the intention is to avoid tax or where there is something showing a lack of good faith or a presence of moral dishonesty


c) Section 98 deals with tax avoidance schemes involving transactions which are abnormal or not at arm’s length. Given the Elite interpretation of section 23 (1) there appears to be little room left for an alternative application of section 81. Section 21 (1) would appear to cover most, if not all, sales than fair market price.


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application of section 81. Section 21 (1) would appear to cover most, if not all, sales than fair market price.


1.4

d) Paragraph 8 of the Fourth Schedule and paragraph 8 of the Fifth Schedule give the Commissioner powers to re-allocate the purchase price (with or without a section 23 adjustment) in a transfer of assets which rank for the capital allowances. These powers are mandatory not discretionary . They would not be applicable where the transfer is made under cover of the elections contained in these Schedules which allow the transfer of the assets to be made at their written down tax values. Paragraph 8 of the


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elections contained in these Schedules which allow the transfer of the assets to be made at their written down tax values. Paragraph 8 of the Fifth Schedule can also operate to adjust the amount which is to be treated as a recoupment of the allowances in the hands of the seller.

These powers of the Commissioner are expressed in wider terms. He can apply them if he is not satisfied with the allocation made.


1.52 International

i) The Legislation: The relevant legislation is contained in section 19, 24, and 98 of the Income Tax Act.

ii) Section 19 is not applicable to the business of insurance. Section 19 and 23 (2) have been held to apply where products are exported from Zimbabwe without prior sale.

iii) The local case of ITC 1103 (1967), 29 SATC 35, is a useful reference for


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Zimbabwe without prior sale.iii) The local case of ITC 1103 (1967), 29 SATC 35, is a useful reference for

understanding the procedure to be followed where these sections are applied. The local case of Mining and manufacturing Co v COT (1944) (SR), 13 SATC 146, dealt with similar legislation. The taxpayer was a foreign company that mined asbestos with similar legislation . The mineral was reduced to cobbed asbestos before being railed to the taxpayer’s factory outside Zimbabwe where asbestos cement was manufactured and sold.


1.6

iv) The court ruled that section 19 operated to tax the exports on the basis of the fair market price less their costs of production. The following aids to interpreting section 19 and 23 (2) come from this decision...

• Section 23 (2) is applicable where the thing exported is, in essence, the thing which is ultimately sold and, therefore, did not apply to the cobbedasbestos


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thing which is ultimately sold and, therefore, did not apply to the cobbedasbestos

• Both section 19 and section 23 (2) apply the same principle, albeit to slightly different circumstances, in order to tax profits from sources within Zimbabwe

• The two provisions are expressly linked by the words in Section 23 (2) connecting it with section 19and the expression “the proportionate part of any profit” in section 23 (2)

• The cost of the raw materials is not a basis for allocating the ultimate taxable profit


1.7

v) Section 24 operates where there are business or financial relationships between interconnected parties here and outside Zimbabwe. Its provisions are repeated in double taxation agreements entered into by Zimbabwe with other nations in terms of section 98.

If conditions are imposed which are not at arm’s length, the Commissioner may determine the taxable income as if the conditions did


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If conditions are imposed which are not at arm’s length, the Commissioner may determine the taxable income as if the conditions did not exist.


1.8

vi) The double taxation agreements operating in terms of section 91 are numerous and cannot be dealt with in this paper

vii) Section 98 is another string to the Commissioner’s bow and would usually be relied upon as an alternative to the sections of the Act referred to above. It remains to be seen whether section 98 can actually provide


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be relied upon as an alternative to the sections of the Act referred to above. It remains to be seen whether section 98 can actually provide something more to the powers given to the Commissioner by these sections.


3. The taxpayer has the right of objection and appeal to any application of all the Commissioners powers referred to above.


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22 DOUBLE TAX AGREEMENTSDOUBLE TAX AGREEMENTSGENERAL PRINCIPLESGENERAL PRINCIPLES

The following principles are applicable at all stages in respect of either DTA:

• if an amount is not taxable in terms of the domestic tax law, the DTA

cannot empower its taxation

• there is no need to look to a DTA for relief against Zimbabwe tax if our

domestic tax law does not impose tax


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• a DTA operates to reduce or erase any disadvantageous effects of double

taxation under domestic tax law, not to impose tax

• if the DTA requires that an amount be subject to tax in either of its two

contracting nations, it will explicitly say so

BDO Tax & Advisory Services (Pvt) LtdBDO Tax & Advisory Services (Pvt) LtdBDO Tax & Advisory Services (Pvt) LtdBDO Tax & Advisory Services (Pvt) LtdBDO Tax & Advisory Services (Pvt) Ltd2 GENERAL PRINCIPLES (2 GENERAL PRINCIPLES (con’tdcon’td))

• A DTA may operate to: exempt amounts from the tax of one of its two

contracting nations; reduce the rate of tax on amounts in one of its two

contracting nations; or, allow the tax chargeable by one of its two

contracting nations on amounts from sources within it as a credit against

the tax chargeable by the other contracting nation on the same amount.


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the tax chargeable by the other contracting nation on the same amount.

• Double taxation relief allowed in the form of a credit against Zimbabwe tax

is calculated as the lesser of the Zimbabwe tax and the tax of the other

contracting nation; and the Zimbabwe tax is calculated on a top-slice basis.


3 CONCEPT OF A PERMANENT ESTABLISHMENT3 CONCEPT OF A PERMANENT ESTABLISHMENT

• Main use of the concept of a permanent establishment is to

determine the right of a Contracting State to tax the profit of an

enterprise of the other Contracting State.

• A Contracting State cannot tax the profits of an enterprise of the

other Contracting State unless it carries on its business through a

permanent establishment situated therein.


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permanent establishment situated therein.


DTA s AND TPDTA s AND TPSection 24 of the ActSection 24 of the Act

Special provisions relating to determination of taxable income in accordance with double taxation agreements

The Commissioner may—

(a) if any person—

(i) carrying on business in Zimbabwe participates directly or indirectly in

the management, control or capital of a business carried on by some


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other person outside Zimbabwe; or

(ii) carrying on business outside Zimbabwe participates directly or indirectly

in the management, control or capital of a business carried on by some

other person in Zimbabwe; or

(iii) participates directly or indirectly in the management, control or capital

both of a business carried on in Zimbabwe by some other person and

of a business carried on outside Zimbabwe by some other person; and


DTA s AND TPDTA s AND TPSection 24 of the ActSection 24 of the Act

(b) if conditions are made or imposed between any of the

persons mentioned in paragraph (a) in their business or

financial relations which, in the opinion of the

Commissioner, differ from those which would be made


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between 2 persons dealing with each other at arm’s length;


CONCLUSIONCONCLUSION

• Tax authorities worldwide are scrutinizing transfer pricing more closely than ever.

• Current Zim tax legislation does not contain specific transfer pricing

provisions;


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• It is therefore necessary to enact legislative provisions that clearly incorporate the use of arm’s length principles in controlling transfer pricing.

• MOF - study will be commissioned to incorporate standard transfer pricing guideline best on international best practice .


QUESTIONSQUESTIONS

QUESTIONS ?????


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THANK YOU

[email protected]

BDO Tax & Advisory Services (Pvt) LtdBDO Tax & Advisory Services (Pvt) LtdBDO Tax & Advisory Services (Pvt) LtdBDO Tax & Advisory Services (Pvt) LtdBDO Tax & Advisory Services (Pvt) LtdDISCLAIMERDISCLAIMER

Whilst every effort has been made to present the most current, correct and clearly expressed information possible, inadvertent errors can occur and are subject to change. The information is intended to serve as a general guideline and may not apply directly to specific


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guideline and may not apply directly to specific circumstances. Nothing in this presentation should be construed as advice and professional advice should be sought before acting thereupon.

Copyright of this publication rests with BDO Zimbabwe Chartered Accountants All rights reserved. Copying of this information, in whole or in part, is prohibited without prior written permission.

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Transfer pricing Thin capitalisation International tax ... · ICAZ Transfer pricing Thin capitalisation International tax planning Presented by : Max Presented by : Max Ngorima Ngorima