Covid 19: Is Safe Habour Still Safe in the Administration of Transfer Pricing by Ezekiel Archibong
Over time, there has been a global consensus to treat multinational enterprises (“MNEs”) as separate entities for tax purposes and transfer of goods and services. This means that, although in practice the enterprises are related entities under the ownership and control of a parent company, they must give their respective accounts based on the fiction that they transact as independent entities. This is known as the Arm’s length principle.
However, for a while now, taxpayers and tax administrators have continued to grapple with the complexities embedded in Transfer Pricing (“TP”) analysis occasioned by the Arm’s length principle. These complexities often lead to uncertainties, TP risks, are time-consuming, and increase compliance costs. To simplify TP compliance and provide certainty on the treatment of related party transactions, tax administrators in different jurisdictions have adopted a more simplified measure. This measure is known as the “Safe Harbor Rule”.
June 2020 Edition
At The People’s Accolade Law Magazine (The PALM), we find pleasure in keeping you up to speed with developing trends in the society.
In this edition, we bring to you our June Deluxe Edition with a focus on Tax Administration and Practice in Africa and it features Kenyan’s Tax Topliner, Emma Kithinji.
Privacy Policy, Data Protection and Inter-jurisdictional enforcement of Data rights; Meeting the Realities of the New Normal By Stanley O. Omotor
Privacy policies are policies which are intended to educate internet users and regulate how digital information is collected, why they are collected, and how they are managed. Organizations with digital platforms are required to have privacy policies to regulate the collection and use digital information, especially personal data.
To aid a realistic analysis of the topic, we will be analyzing the provisions of Google Privacy Policy (“GPP”) . The preference of the GPP for analysis, rather than any other privacy policy, is informed by the reason that Google is one of the most populous digital service provider globally as almost all internet and phone users interact with one form, or the other, of the digital services provided by Google. Popular Google applications (“apps”) and platforms include Google search, YouTube, G-mail, Chrome browser, Google Play Store, Google Map and the Android operating system. For instance, the Android operating system is reputed to be the largest installed base of any operating system worldwide controlling the global operating system market with a 74.13% share.
Artificial Intelligence and Lawyer: The Fear of Change/Redundancy by Kingsley Akposheri
Artificial Intelligence (“AI”) and law is a subfield of artificial intelligence which is mainly concerned with the application of AI to the problems of legal informatics and original research on those problems. It is also concerned with contributing in the other direction: to export tools and techniques developed in the context of legal problems to AI in general. For instance, theories of legal decision making, especially models of argumentation, have contributed to knowledge representation and reasoning; models of social organisation based on norms have contributed to multi-agent systems; reasoning with legal cases has contributed to case-based reasoning, and the need to store and retrieve large amounts of textual data has resulted in contributions to conceptual information retrieval and intelligent databases.
Police conduct during the lockdown vis-a-vis their powers and mandate by Alfayo Ongeri Wycliffe
The outbreak of covid-19 has seen countries across the globe impose and deploy various measures in an attempt to reduce infections, flatten the curve and return to normalcy. The African continent and the East African Community have not been left out. So far Rwanda and Uganda are under a total lockdown with Rwanda being the first country in Africa to do so while Kenya has imposed a dusk-to-dawn curfew throughout the Kenyan territory
This Covid 19 Woman, was a Beacon of Hope By Dan Odhiambo
Wuhan, the rambling capital of Central China’s Hubei region, is a business community separated by the Yangtze and Han waterways. While the pronunciation of this city remains a debacle, its rays are forever embedded in the annals of history. Whilst history students are putting down pen on pad for future review, t
Justice Delivery in Nigeria in the Face of a Global Pandemic: Opinion – ‘Tobiloba Adekoya.
In light of the ongoing global pandemic (Covid-19) ravaging almost all countries of the world, legal proceedings in Nigeria and other countries of the world have been stalled. The Kenyan judiciary took the lead in innovative justice delivery in Africa when images of a Kenyan judge conducting court proceedings via an online platform surfaced. This approach has being maintained so far in the face of the pandemic. This innovative approach to justice delivery is to say the least revolutionary and worthy of commendation as it has opened a new vista in the realm of justice delivery.
April 2020 Edition
At The People’s Accolade Law Magazine (The PALM), we find pleasure in keeping you up to speed with developing trends in society.
In this edition, we bring to you our April Deluxe Edition with a focus on Intellectual Property and it features Africa’s cerebral Poet, ‘Tolu Akinyemi “Poetolu”.
Care for the Elderly in Nigeria- The Need for the Intervention of the Elder Law by Ogundele and Adeoye
Access to education and recent improvement in the medical field across the globe, has not only contributed to global development, but also improved human lifespan, Nigeria is no exception. Morbidity rate has been minimised
Franck Allessie: Africa’s Legal Millennial
Franck Allessie, a PhD thesis candidate at the University of Paris whose research focuses on the analysis of Public-Private Partnership (PPP) agreements and its geo-economic issues in the West and Central African sub-regions is indeed a notable personality to be mentioned.
For several years now, he has acquired, as a counsel to public persons (State, public institutions and local authorities), financial institutions, multinationals, large companies, NGOs, a rich and varied experience in the field of public-private partnerships (PPP), DSP, public procurement in the execution of contract…
