About

SubstanceIQ is written by Jelena Mihić Munjić, a certified auditor who spends her working life on the question this letter is about: whether what a file says a company does is what the company actually does.

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She is Managing Partner of Kreston MDM Serbia, a firm of 45 people serving more than 300 clients, and Chair of Kreston Global Europe, which covers 830 offices across 114 countries. She sits on the supervisory board of UniCredit Bank Serbia.

She holds the ACCA qualification and an MSc in economics, and is a certified auditor. Before moving into audit she was a dealer and portfolio manager at the National Bank of Serbia. Her writing on transfer pricing has been published by Bloomberg Tax and International Tax Review.

What this letter argues

That economic substance has to stop being a matter of narrative and become a matter of measurement.

A transfer pricing file describes who makes decisions, who controls risk, who could have decided otherwise. Those are claims about how an organisation behaves, and an organisation leaves a record of how it behaves — in approval histories, access rights, escalation paths, incident logs. The file and the record should say the same thing. Very often nobody has checked whether they do.

That gap is what the letter is for.

What it is not

It is not advice on any specific matter, and reading it does not create any professional relationship. Views expressed are the author’s own and are not those of Kreston MDM, Kreston Global, or any other organisation she is associated with.

Getting in touch

The most reliable route is LinkedIn.