30 Seconds With...Mlondie Mohale, Manager International Transactions, Large Taxpayer Unit, Swaziland Revenue Authority
We have just under a week until Africa’s premier forum for corporate transfer pricing leaders and their advisors, TP Minds Africa. In preparation, we talked to Mlondie Mohale about the current transfer pricing landscape across the continent.
What are you currently spending most of your time on?
Interestingly enough, the focus has changed from the primary objective of developing ways to reduce the effective tax rate to assessing the risks of tax arrangements. A call for transparency within corporations when it comes to their TP arrangements has been my order of day.
What is the biggest challenge facing Transfer Pricing professionals in your particular industry at the moment?
BEPS changes are being ‘decoded’ significantly within the rapid international tax fraternity. Corporations are indeed becoming more transparent in their TP arrangements and tax authorities have to deliver a fully comprehensive global approach to tackling transfer pricing abuses.
What should a successful post-BEPS transfer pricing strategy look like?
- Profits should be aligned with the location of value creation.
- TP Policies should exert significant emphasis on economic ownership and control rather than legal ownership
The list is endless, and it could be at least a couple of years before we even have a clear picture on how in practice the different actions will be applied within the relevant territories.
Which areas of TP do you think the next wave of transfer pricing controversy will come from?
I foresee quite some discussion centered on the ‘Value Chain Analysis’. Have you noticed that almost every article has to one way or the other include BEPS today? Actions 8-10 have fortified the significance of aligning profits with value creation, which is quite complex in practice.
Which jurisdictions are likely to be keeping the Head of TP awake at night?
European countries have kept heads rolling, however there has been an increase of TP risk assessments and audits within African countries of late.
What advice would you give an aspiring TP professional?
Keep on learning! TP rules are evolving, so revisit your model to ensure a spot on review of possible discrepancies between the actual value drivers and the overall TP outcome.
You will be speaking at TP Minds Africa next week. What are you most looking forward to?
It’s TP Minds Africa after all, so I am excitedly looking forward to the exchange of views with ultimate sharing of ideas!
Tell us a little known fact about yourself.
I read a lot and analyze just about everything I read. Also when it comes to movies, can we just finish watching one without anyone asking questions?
