An international specialist in transfer pricing and cross border taxes.

Bridging the knowledge and skills gap.

Transfer pricing and cross border taxes are currently among the most challenging international tax topics faced by multinational enterprises around the world. The OECD BEPS measures, and more recently the Global Anti-Base Erosion (GloBE) Pillar 1 and Pillar 2 rules, are highly complex and demand detailed attention and specialised skills.

This complexity has created a significant knowledge and skills gap, a serious challenge for both tax authorities conducting compliance audits and the multinational enterprises working to remain compliant. TPTAX is the right partner to help bridge that gap through research, training and limited scope advisory support across Africa and the Middle East (GCC countries).

Research

Continuous technical research and publications on transfer pricing, cross border taxes and Pillar 2 developments.

Training

Practical training on benchmarking tools, transfer pricing, cross border taxes and Pillar 2 rules.

Limited Scope Advisory

Focused advisory support on transfer pricing issues, cross border taxes and Pillar 2 calculations.

Over 26 years of tax expertise, including 18 years specialising in transfer pricing and cross-border taxation across Africa and the Middle East.

Puleng Owen Manyaka is the Executive Director and CEO of TPTAX.co for Africa and the Middle East (GCC). With more than 26 years of experience in taxation, he has built an extensive career spanning transfer pricing, cross-border and international taxation, corporate income tax, VAT, personal income tax, and PAYE/payroll taxes.

Throughout his career, Puleng has held senior leadership positions at EY, SAICA, ABB Southern Africa, and a national tax authority. His experience includes serving as Transfer Pricing Executive, Project Director: Tax, Head of Tax for Sub-Saharan Africa, and Executive: Transfer Pricing and International Tax, advising on complex tax matters across multiple jurisdictions.

He previously served on the OECD Working Party 6 (WP6), the committee responsible for shaping global transfer pricing guidance, and has contributed to several SAICA tax legislative policy committees, including the SAICA Transfer Pricing Committee.

Passionate about developing technical expertise, Puleng is actively involved in tax research and academia. He has supervised and externally examined postgraduate research for the Master of Commerce (Taxation) programme at the University of Pretoria School of Accounting, helping to advance knowledge and professional capability in transfer pricing and international taxation.