Africa: Tax

This article was developed from the conversations at the Beyond Borders Tax Webinar

Estate planning extends far beyond drafting a valid Will. This article examines the critical but often overlooked issue of estate liquidity—the availability of cash to settle taxes, debts, and administration costs—and explains why asset-rich estates can still face serious financial challenges during administration.

A landmark High Court ruling in Uganda has fundamentally altered how the 30% tax deposit requirement applies when taxpayers challenge assessments before the Tax Appeals Tribunal.

Instalment sale agreements offer flexibility in South African property transactions, but many purchasers misunderstand when transfer duty becomes payable. Under Section 20 of the Alienation of Land Act, transfer duty liability may arise at the date of agreement signature—long before ownership actually transfers—creating unexpected financial obligations that require careful legal and tax planning from the outset.

On 31 October 2025, the General State Budget Bill for 2026 ("2026 GSB Bill") was submitted to the Angolan National Assembly (parliament).

Taxation as a crucial fiscal policy measure is a factual tool for social economic development, which has been adopted by various countries around the world to improve their economic goals.

Higher education institutions are navigating an increasingly complex tax landscape as they diversify revenue streams, expand internationally, and transform their operational models. From VAT complications on mixed activities to intricate employee taxation and global mobility challenges, universities face mounting compliance pressures that demand strategic attention and proactive management.

This article examines the implications of Nigeria's tax administration transition for enterprises regulated by the Nigeria Export Processing Zones Authority (NEPZA) and the Oil and Gas Free Zones Authority (OGFZA). It considers the pre-reform legal position, the structural changes introduced by the Nigeria Tax Administration Act, and how those changes affect NEPZA and OGFZA regulated entities.

Nigeria's Federal Ministry of Finance has issued comprehensive transition guidelines to bridge the gap between repealed tax laws and the new Tax Acts 2025, addressing critical questions about compliance obligations and the treatment of transactions during this pivotal period.

The European Commission's Taxation Omnibus introduces sweeping amendments to five key EU tax directives, aiming to simplify decades of accumulated complexity while maintaining protections against tax avoidance. These reforms promise broader withholding tax exemptions, new R&D allowances, and alignment with international Pillar Two standards, potentially reshaping cross-border business operations across the EU by 2029.

Uganda is proposing significant changes to how it taxes cross-border debt. The Income Tax (Amendment) Bill, 2026 would introduce a new 5% withholding tax on certain interest payments that are currently exempt.

The 2025 Update to the OECD Model Tax Convention Commentaries provides guidance on when a home or remote location can give rise to a fixed place of business PE under Article 5(1).