Current Project

An Empirical Study for the Case for the Introduction of Advance Pricing Agreements in Low and Lower-Middle Income Countries

The study will primarily take the form of a comparative case study of the transfer pricing regimes in Indonesia, Vietnam, Nigeria and Uganda. The comparison will examine the state of Tax Policy disputes before the introduction of Advanced Pricing Agreement regimes in the respective countries as well as after the introduction.

In addition, through this study, the researchers aim to understand the difference between the amount of information necessary and available under the APA regime as compared to the data collected under TP audit and litigation. They aim also to draw a general picture of the type of taxpayers that opt to seek APAs in order to understand how sophisticated they are and if there is information asymmetry between the taxpayers and revenue administrators. They will also evaluate the link between tax administration resources for audit and MAP vis-a-vis the use of APAs. Finally, they will assess what general challenges tax administrators have faced while using the APA regime as well as positive outcomes. This will consider the implications of using unilateral, bilateral, and multilateral APAs.

Researchers

Prisca Musibi

Prisca Musibi is an early career tax researcher. She has diverse experience in domestic and international tax law from her time at a leading Big 4 firm in Nairobi, as well as engagements with think tanks in Nairobi and Geneva. Prisca holds an LL.M specialising in International Taxation from the University of Cape Town, South Africa, and is an advocate of the High Court of Kenya.

Mary Ongore

Mary Ongore is a Kenyan legal professional with extensive experience in taxation. She holds an LLB degree from the University of Leeds, and an LLM in Tax Law from Queen Mary University of London. She is a PhD candidate at the University of Nairobi, specialising in tax. Her research revolves around international tax, fiscal policy, and illicit financial flows. Mary worked as a Tax Advisor at KPMG in the UK, and an employment tax advisor at Zurich Insurance in the UK. She has since worked for Strathmore University as a Doctoral Fellow, at the University of Nairobi as a Tutorial Fellow, and at Dentons Hamilton Harrison & Mathews as a Tax Associate. She has conducted research on tax and gender, tax treaties, tax and human rights, and taxpayers’ rights as an independent consultant
Research theme:
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