IT IS very common for a group of companies to provide loans to one another. The primary reason is to utilise the internal funds before going to external sources because inevitably it will be cheaper. The opportunity cost to the lender will be the key consideration. If...

THE Global Minimum Tax (GMT) was introduced to address profit shifting by very large multinational enterprises (MNE) to low-tax or tax-free jurisdictions, which resulted in double non-taxation. In many cases, the MNE were either not taxed in their home jurisdiction or...

THE Mutuality Principle is a principle that is not commonly used and understood by many taxpayers. The underlying concept is a simple proposition that members of an association cannot make profits if they are dealing with themselves. An example would be a camping club...