11Protecting & Transforming Value
Tax, Transfer Pricing & Business Succession
Structuring Value. Preserving Wealth. Securing Continuity.
Tax is one of the strongest determinants of enterprise value, investment performance and long-term wealth preservation.
Sound tax governance supports capital formation and provides certainty. Poor tax governance creates cost, exposure, disputes and reputational risk.
Platform
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Protecting & Transforming Value — Preserving enterprise value under stress, resolving what is contested, and protecting what has been created.
Practice engine
TED
Purpose
Tax is one of the most significant determinants of enterprise value, investment performance and long-term wealth preservation. Sound tax planning supports capital formation, enhances competitiveness and provides certainty for business growth. Poor tax governance, by contrast, creates unnecessary cost, regulatory exposure, disputes and reputational risk.
Equally, the continuity of an enterprise depends not only on financial performance, but also on the orderly transition of ownership, leadership and stewardship across generations.
The Tax, Transfer Pricing & Business Succession Advisory Platform exists to help clients make informed decisions that optimise value, strengthen governance and preserve enterprises for the future.
Why this matters
Tax is no longer viewed simply as a compliance obligation.
Boards, governments and investors increasingly recognise tax as a strategic business issue that influences investment decisions, financing structures, mergers and acquisitions, supply chains, cross-border operations and shareholder returns.
At the same time, family-owned enterprises---many of which drive Africa's economies---face significant challenges in preserving wealth and ensuring orderly succession. Without robust governance and succession planning, successful businesses can be weakened by uncertainty, fragmentation and inter-generational disputes.
Governments are also strengthening tax administration, implementing international standards and increasing scrutiny of cross-border transactions.
What we do
The Platform delivers integrated advisory across ten strategic service lines.
Corporate Tax Advisory
- Corporate income tax
- International taxation
- Withholding tax
- VAT and indirect taxes
- Stamp duties
- Tax incentives
- Investment structuring
- Tax-efficient financing
- Sector-specific tax regimes
- Tax implications of commercial transactions
Transaction Tax
- Mergers and acquisitions
- Joint ventures
- Corporate reorganisations
- Project finance
- Infrastructure investments
- Private equity transactions
- Capital restructuring
- Cross-border acquisitions
- Exit strategies
- Transaction due diligence
Transfer Pricing
- Transfer pricing policies
- Functional and economic analysis
- Benchmarking
- Documentation
- Country-by-country reporting
- Master and local files
- Intra-group financing
- Intangible assets
- Business restructurings
- Advance pricing arrangements
Tax Governance
- Board oversight of tax
- Tax risk management
- Tax control frameworks
- Tax governance policies
- Governance reporting
- Internal controls
- Regulatory engagement
- Tax health reviews
- Enterprise tax strategy
Tax Controversy & Dispute Resolution
- Revenue authority audits
- Tax investigations
- Voluntary disclosures
- Objections
- Administrative reviews
- Tax appeals
- Settlement negotiations
- Litigation
- Cross-border tax disputes
Private Wealth Advisory
- Wealth structuring
- Asset protection
- Family investment structures
- Cross-border wealth planning
- Philanthropic structures
- Family offices
- Investment governance
- Long-term wealth preservation
Family Governance
- Family constitutions
- Family councils
- Governance charters
- Shareholder arrangements
- Family employment policies
- Conflict management
- Next-generation leadership development
- Family decision-making frameworks
Business Succession
- Succession strategy
- Ownership transition
- Leadership succession
- Estate planning
- Trusts
- Foundations
- Holding company structures
- Shareholder continuity
- Enterprise preservation
- Multi-generational planning
International Structuring
- Cross-border investments
- Regional holding structures
- Investment treaties
- International tax coordination
- Double taxation agreements
- Global mobility
- Foreign investment planning
Strategic Tax Reform
- Tax policy reviews
- Legislative reform
- Revenue mobilisation strategies
- Investment incentive design
- International tax implementation
- Institutional strengthening
- Capacity development
Tax Litigation & Dispute Resolution
Tax disputes are won or lost long before the hearing — in how the audit is managed, what is conceded in correspondence, and whether the objection preserves the arguments that matter. We run tax disputes as litigation from the first information request.
- Audit management and defence: scope negotiation, information requests, privilege, and controlling the factual record
- Objections, administrative review and the strategic framing of grounds
- Alternative dispute resolution and mediated settlement with revenue authorities
- Tax Appeals Tribunal proceedings, and appeals to the High Court, Court of Appeal and Supreme Court
- Judicial review of revenue decisions where the issue is legality, jurisdiction or procedural fairness rather than quantum
- Interim relief, agency notices, distress, garnishee and enforcement action, and applications to restrain or suspend collection
- Penalty and interest mitigation, and remission applications
- Transfer pricing and cross-border disputes, including mutual agreement procedure and competent authority engagement
- Sector-specific controversy in extractives, financial services, telecommunications and infrastructure
Negotiations, Private Rulings & Revenue Authority Engagement
Certainty is usually worth more than victory. Where a position can be settled in advance, we settle it in advance.
- Private and advance rulings: assessing whether to seek one, framing the facts, and managing the consequences of the answer
- Advance pricing arrangements, unilateral and bilateral
- Negotiated settlements, instalment and payment arrangements, and waiver applications
- Voluntary disclosure and regularisation programmes
- Pre-transaction clearances and confirmations on reorganisations, incentives and treaty entitlement
- Sustained regulatory engagement: building the institutional relationship with the revenue authority before it is needed
Tax Strategy
Tax strategy is a board matter. It sets the risk appetite within which every position is taken, and it is increasingly a matter of public and investor scrutiny.
- Board-level tax strategy and tax risk appetite statements
- Effective tax rate analysis, forecasting and management within the law
- Group structure and holding chain review against substance, treaty entitlement and anti-avoidance exposure
- Incentive and exemption strategy: qualification, protection, and defence on review
- Tax in transaction and financing structuring, including the fiscal cost of alternative structures
- Tax control frameworks, documentation standards and audit readiness
- Reputational and public-interest dimensions of tax positions, including responsible tax reporting
- Tax policy engagement and law reform contribution on behalf of industry and institutional clients
Signature solutions
Defined pieces of work that address the needs this platform meets most often. Each can be scoped and commissioned on its own.
Enterprise Tax Governance Review
An assessment of the tax governance framework, compliance posture and strategic tax risks an organisation carries — delivered as a board-ready risk register with recommended controls, ownership and an escalation route, so that tax stops being discovered at audit.
Transfer Pricing Readiness Programme
Policies, documentation, intercompany agreements and governance brought into alignment with domestic legislation and international standards — with the local file, master file and defence position prepared before the authority asks, not after.
Family Enterprise Continuity Programme
Family governance, ownership structuring, tax planning and succession combined into one roadmap: who owns, who governs, who leads, who is bought out, and on what terms — so that ownership transitions without the enterprise, the tax position or the family fracturing.
“A tree is best planted by one generation, and its shade enjoyed by another.”
How we deliver
- Understand the client's strategic, commercial and family objectives
- Assess the legal, tax, governance and commercial environment
- Identify risks, opportunities and structural options
- Design an integrated tax, governance and succession strategy
- Implement the agreed structures and documentation
- Support regulatory engagement and implementation
- Monitor performance and adapt structures as circumstances evolve
- Strengthen long-term governance and enterprise continuity
Representative mandates
- Advising on tax-efficient acquisition and investment structures
- Designing transfer pricing frameworks for multinational enterprises
- Supporting business families with governance and succession planning
- Advising governments on tax policy and legislative reform
- Representing clients in complex tax disputes and investigations
- Structuring regional holding companies and cross-border investments
- Establishing trusts, foundations and family office structures
Illustrative. Client names and commercial details are withheld where confidentiality obligations apply.
Why Ligomarc
Tax is not merely about compliance. It is about enabling investment, preserving enterprise value, supporting commercial growth and ensuring continuity across generations.
Ligomarc brings together expertise in tax, finance, corporate governance, family enterprise advisory, investment structuring, disputes and strategic transactions to provide integrated solutions tailored to each client's objectives.
Our multidisciplinary approach enables clients to structure investments efficiently, strengthen governance, navigate increasingly complex tax environments and preserve wealth and enterprise value for future generations.
Through this Strategic Advisory Platform, Ligomarc helps Enterprises, Governments, Financiers and Infrastructure Players build, finance, govern, transform and protect institutions, investments and enterprises that contribute to Africa's long-term prosperity.
Institutional Experience Applied. We have negotiated with a revenue authority as the officer responsible for a distressed national enterprise — arrears, penalties, agency notices and enforcement action, with payroll to meet the same month. That perspective shapes how we run controversy. Our constitutional office experience governs how we approach the legality and procedural fairness of revenue decisions, and our arbitration work covers the treatment of tax in international awards.
Platform leadership
Regional & continental frameworks
The OECD/G20 Inclusive Framework on BEPS including the two-pillar solution; the African Tax Administration Forum model approaches; the UN Model Convention and the emerging UN framework convention on international tax cooperation, in which the Africa Group has been the driving force; the EAC and COMESA tax harmonisation agenda and regional double taxation agreements; national income tax, VAT, stamp duty, succession and trustee legislation.
Contribution to the African Purposes
Strongly supports African Family Businesses — this is the platform on which generational continuity is built. Honours African Culture & Heritage by designing succession around African family realities rather than imported templates. Advances African Institutional Stewardship through tax policy, revenue authority engagement and lawful, transparent tax positions. Advances African Continental Integration through regional structuring and treaty work. Part III — Enabling Future Value
Selected experience
All experience →Central bank
Reported
Tax dispute protecting approximately UGX 60 billion
A revenue authority assessment against the central bank created material fiscal exposure and raised questions with implications well beyond the assessment itself.
- Tax
- Disputes
Multi-country family-owned manufacturing group
Reported
Family-enterprise continuity architecture for a multi-country manufacturing group
A family-owned manufacturing group operating across several African markets needed to combine ownership, governance, tax and succession into a single continuity plan before the next generational transition.
- Tax
- Succession
- Manufacturing
Global oilfield services contractor
Reported
Tax controversy concerning approximately UGX 22 billion
A multinational contractor operating in the oil and gas sector faced a significant assessment turning on cross-border structuring and the treatment of services delivered into the jurisdiction.
- Tax
- Oil & Gas
Who we serve with this
Discuss a tax, transfer pricing & business succession mandate.
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