Optimising shared and central costs for a Pan-African Fintech group

Client Overview

A fintech group with operations across multiple African countries approached us to address concerns about how they allocated and charged central costs to their various entities. Despite having Transfer Pricing documentation prepared by a Big 4 firm, the group found their current cost-sharing model inefficient and tax-intensive.

Specialist Services Used:

Goals

  • Develop an efficient and compliant method for allocating central costs to operating companies, considering specific Transfer Pricing (TP) regulations, particularly in Kenya.
  • Reduce the impact of withholding taxes and irrecoverable VAT on imported services, emphasising countries where VAT and withholding tax present significant regulatory challenges.
  • Ensure alignment between intellectual property (IP) ownership and the group’s operational realities to mitigate future tax risks, avoiding excessive cost allocations that may trigger additional tax scrutiny.

Our Recommendations

Working closely with both the Transfer Pricing and African tax teams, we conducted an in-depth analysis and recommended the following:

01.

A revised intercompany charging method with a cost allocation model more aligned with the group’s commercial activities, effectively reducing VAT and withholding tax obligations.

02.

IP ownership and Transfer Pricing alignment. We realigned the group’s IP ownership and development practices with a tax position accurately reflecting commercial realities, minimising potential future tax exposure.

03.

A tax-efficient structuring of shared services to centralise intellectual property management while allowing the operating companies to benefit from its use without incurring inefficient tax costs.

Outcomes (To Date)

The recommended model led to immediate tax savings by reducing withholding and VAT burdens, with further benefits from a clarified and defensible IP ownership structure. This approach aligns with commercial reality and gives the group a more robust tax position across African operations.

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