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Deus Mugabe

Deus

PhD Student

Email: d.mugabe@qmul.ac.uk

Profile

Thesis title

Transfer pricing challenges faced by developing countries.

Supervisors

Summary of research

The taxation of Multinational Enterprises (MNEs) remains a difficult mission for countries where they conduct business and earn profit. One of the central challenges faced by the various countries where MNEs conduct businesses and earn profit is how the profits of the MNEs should be allocated amongst them.

The current international tax framework attempts to solve this problem by applying transfer pricing rules. The transfer pricing rules are based on the Arm’s Length Principle (ALP), which posits that associated enterprises should be treated as separate entities for purposes of ascertaining the appropriate prices of intragroup transfers of goods and services.

The application of the ALP presents daunting challenges to both the MNEs and tax administrations. Some of the challenges faced by MNEs include; high costs of documentation, uncertainty of outcomes, lengthy audit procedures. Tax authorities, and especially those in developing countries, face inter alia, capacity challenges, resource constraints, flawed legal framework and lack of comparables. 

This research seeks to identify and examine the challenges faced by developing countries in the application of transfer pricing rules.

Biography

Mr Mugabe holds an LLM in Tax Law (with Distinction) from Queen Mary University of London. He is an advocate of the High Court of Uganda with a deep and broad understanding of Uganda’s legal system. Before returning to Queen Mary for his PhD studies, Mr Mugabe acted as a tax partner and head of the taxation department at H&G advocates (a leading and oldest commercial law firm in Uganda). 

Mr Mugabe’s practice focuses on international tax planning and advisory, transfer pricing, tax litigation, constitutional law, corporate and commercial law practice, mergers and acquisitions, banking and finance law, and civil litigation. He has been involved in some of the largest M&A deals and transfer pricing cases in Uganda.  

Mr Mugabe taught revenue law and taxation at Makerere University School of Law. He also lectured international taxation and transfer pricing at the East African School of Taxation.

Publications

  • Deus Mugabe, “Mugabe on Insolvency Law in Uganda,” (2022)

Speaking engagements

  • He is often invited to make presentations to the Uganda Law Society during the annual insolvency and tax law symposium.

Studentship

  • Queen Mary University of London, HSS Principal Studentship.

Research

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