Abstract
Increased global trade liberalisation, fuelled by favourable multilateral trade agreements, mainly Article VII of the General Agreement on Tariffs and Trade 1994 (GATT 1994) was the genesis of a new world order characterised by the proliferation of a large number of once domesticated corporates establishing presence beyond domestic markets. The direct result of the rapid global presence by corporates was the birth of an estimated 79 000 parent companies with 790 000 foreign affiliates (both collectively referred to as Multinational Entities) by the end of 2007. Predictably, the establishment of operations in new foreign markets by Multinational Entities (MNEs) led to a spike in the flow of goods between members of the same MNE group. By 2015, the International Chamber of Commerce reported that 60% of global trade in terms of value comprised of intercompany transactions...
M.Com. (South African and International Taxation)