Insights

Notes on Tax, Written for Practical Use

Perspectives on transfer pricing, international taxation, and GST — drawn directly from the matters we work on.

Two colleagues reviewing documents — Section 166(9) three-year ALP lock-in article
Transfer Pricing

Locking In the Arm's Length Price for Three Years

A practitioner's guide to Section 166(9) and Rule 82 — the new three-year ALP lock-in, with FAQs on documentation obligations and GCC applicability.

Article 2 September 2026
Safe Harbour Rules article — gavel, law books, and scales of justice
Transfer Pricing

Safe Harbour Rules: A Practical Guide for the 2026-27 Block Period

A transaction-by-transaction breakdown of Rules 86-93 — the nine eligible categories, prescribed margins, and revenue caps that determine whether a filing qualifies for safe harbour.

Article 21 July 2026
MKA
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