What are you currently spending most of your time on?
Finalizing the Groups TP document and ensuring that it is in line with OECD standards.
Assisting the Groups FM’s in completing the new CBC template, and working on the Groups Masterfile requirements.
What is the biggest challenge facing Transfer Pricing professionals in your particular industry at the moment?
Completion of the new Income Tax Returns, particularly the TP and International Tax section where historic information that has previously never been required is now required. Also, Interpretation of certain terms used in the CBC reports and Masterfile.
What should a successful post-BEPS transfer pricing strategy look like?
In the spirit of Actions 9 and 10, roles and responsibilities assigned to entities defined by group management would need to be analysed. As much as these have always been documented in contracts, the business reality and not the contract should now be the driver.
Which areas of TP do you think the next wave of transfer pricing controversy will come from?
Mutual agreement procedures, competent authority relief and arbitration procedures.
Which jurisdictions are likely to be keeping the Head of TP awake at night?
In light of the current BEPS initiatives, I think jurisdictions with high taxes since their tax authorities could assume that MNEs are intentionally trying to avoid paying taxes there and therefore always subject to unnecessary audits.
What advice would you give an aspiring TP professional?
In TP, it’s not about who you know, but who knows you.
You recently spoke at TP Minds Africa 2016. What was your favourite part?
Sharing some TP insights with other TP professionals in Africa
Tell us a little known fact about yourself.
Of all the questions asked, this is the one I took the longest thinking about. I can be very self-conscious at times.
Thabiso Mohokare