Your Transfer Pricing Advisor in Eastern Africa

tp2 is an independent firm that advises clients and supports accounting firms and law firms with regard to matters transfer pricing and the valuation of intellectual property (intangibles).


  • Planning – providing economic analysis and implementation support for clients who have restructured.
  • Compliance – preparing transfer pricing policies and other documentation to meet countryspecific transfer pricing legislation (or applying international best practice: OECD Guidelines and US 482 Regulations ).
  • Audit defence– defending clients before revenue authorities where assessments have been raised;
  • Client representation – representing clients before revenue authorities to negotiate transfer pricing methods, etc.


Clients engage us to estimate the value of their:

  • Proprietary Technologies – Including software, etc.
  • Valuable marketing brands – (tradenames, trademarks, service marks), for the purpose of intercompany transfers, etc.


tp2 routinely helps its clients develop transfer pricing policies to meet statutory requirements in line with the rules and regulations in different jurisdictions. In a recent case, we helped a floricultural concern by creating transfer pricing policies for both the Kenya and UK entities. Each of these policies was prepared from a unique country perspective.

Interestingly, an Altus Alliance member firm in South America was able to provide us with data on comparable cut flower growers in South America, including significant Balance Sheet data that allowed us to incorporate working capital adjustments to improve the comparability of comparables acquired.

In addition, we are well paced to make country risk adjustments (say, wage/labour rate adjustments) to improve the comparability of data used.

The tp2 Difference

tp2 commits senior staff to each project allowing its clients to reap the benefits of the experience and technical depth.

tp2 develops innovative solutions, individualized to each client’s needs.

tp2 offers a high level of implementation support and works closely with clients to actualize its solutions.


tp2 routinely applies transfer pricing techniques to solve business problems. In one case, tp2was able to develop a pricing mechanism that achieved a dual purpose: comply with the transfer pricing rules as well as reduce the group’s exposure to withholding tax.


tp2 applies a practical approach to defending taxpayers during transfer pricing audits. By establishing certain goals at the outset of the engagement, tp2 is able to craft a strategy to either reduce the settlement amount or create a robust High-Court-ready defence.

tp2 routinely applies its learning experiences from controversy work to other aspects of transfer pricing in anticipation of potential attacks from revenue authorities.