Transfer Pricing Readiness for U.S.?Africa Mid-Market Supply Chains: Practical Documentation Pathways
Abstract
The article creates a systematic, practice-based framework of transfer pricing (TP) documentation readiness within mid-market U.S.-Africa supply chains. The majority of them are systemically underprivileged: most such businesses are established or operated by immigrant entrepreneurs, which contributes to incomplete data systems, cultural-linguistic gaps (Fashakin, 2023), and lack of regulatory maturity (Chima et al., 2022; Dako et al., 2022). The article has employed comparative caselets in both the technology and distribution industries to prescribe a three-layer documentation model that incorporates scoping of the transaction, methodology selection in the face of imperfect data, and file preparation in accordance with the current situation, both with the IRS and the African tax authority requirements. The model relies on the existing studies on financial control (Adebiyi et al., 2025), cross-border structuring (Shiraishi and Mupa, 2025), and compliance psychology (Hartmann et al., 2020), which offers the mid-sized multinational companies a flexible factor of attaining audit resilience. Applying the synthesis of IRS Treas. Reg. 1.6662-6 to the ATAF and OECD principles, the model indicates that the preparation is not about the quantity of data, but rather the consistency, linking of data, documenting, and purpose (Varyani, 2022).
Keywords
Africa, Mid-Market, Readiness, United States, Transfer-Pricing
Citations
IRE Journals:
Sabelo Nare, Munashe Naphtali Mupa, Catherine Danda, Last Chingezi, Nelia Mlambo "Transfer Pricing Readiness for U.S.?Africa Mid-Market Supply Chains: Practical Documentation Pathways" Iconic Research And Engineering Journals Volume 9 Issue 7 2026 Page 613-623
IEEE:
Sabelo Nare, Munashe Naphtali Mupa, Catherine Danda, Last Chingezi, Nelia Mlambo
"Transfer Pricing Readiness for U.S.?Africa Mid-Market Supply Chains: Practical Documentation Pathways" Iconic Research And Engineering Journals, 9(7)
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