Tax Law and International Tax Law

Botswana's new Income Tax (Transfer Pricing) Regulations, 2026 establish a comprehensive framework for pricing and documenting related-party transactions. The regulations introduce a hierarchical approach to transfer pricing methods, specific requirements for comparables selection, and strict contemporaneous documentation obligations that fundamentally change how multinational businesses must approach their cross-border arrangements.

Cross-border tax compliance between Botswana and South Africa is undergoing significant transformation as SARS deploys AI-driven enforcement tools, Botswana proposes a shift to residence-based taxation, and global minimum...

Investment in the Democratic Republic of the Congo continues to expand across mining, energy, infrastructure, telecommunications and other strategic sectors. Alongside commercial potential, investors must address a question from the outset: how can capital, cash flows and expected returns be protected throughout an investment?

Kenya's Finance Act 2026 introduces significant tax reforms that impact venture capital, private equity, and foreign investment. This discussion explores how these changes affect investor confidence...

Kenya's Finance Act 2026 introduces significant tax reforms that impact investors and businesses operating in the country. This podcast discussion examines the practical implications of these changes, from tax amnesty provisions to REIT incentives, and explores what they mean for Kenya's investment climate. Industry experts analyze how these reforms affect venture capital, private equity, and the broader tax policy landscape over the coming years.

South Africa's Revenue Service has issued Binding Private Ruling 430, clarifying its position on trust-to-trust distributions and the section 7(8) attribution rules. The ruling examines whether distributing an interest-free loan claim constitutes a disposition, explores how the causal nexus can be severed when downstream yields are generated by independent foreign companies, and reveals the administrative complexities trustees face when claiming foreign tax rebates for non-resident beneficiaries.

When SARS disallows or only partially allows your tax objection, you have the right to appeal. Understanding the procedural requirements, strict deadlines, and available dispute resolution options can make the difference between a successful appeal and losing your right to challenge the assessment altogether.

Kenya's Finance Act 2026 introduces significant tax reforms that impact venture capital, private equity, and foreign investment. This discussion explores how these changes affect investor confidence...

Kenya's Finance Act 2026 introduces significant tax reforms that impact investors and businesses operating in the country. This podcast discussion examines the practical implications of these changes, from tax amnesty provisions to REIT incentives, and explores what they mean for Kenya's investment climate. Industry experts analyze how these reforms affect venture capital, private equity, and the broader tax policy landscape over the coming years.

South Africa's Revenue Service has issued Binding Private Ruling 430, clarifying its position on trust-to-trust distributions and the section 7(8) attribution rules. The ruling examines whether distributing an interest-free loan claim constitutes a disposition, explores how the causal nexus can be severed when downstream yields are generated by independent foreign companies, and reveals the administrative complexities trustees face when claiming foreign tax rebates for non-resident beneficiaries.

Africa's emergence as a major investment destination has made the choice of holding company jurisdiction critical for investors targeting Kenyan assets. With over $70 billion in foreign direct investment flowing into the continent, the decision of where to incorporate affects taxation at multiple levels, investor protections, regulatory compliance, and ultimately determines the economic viability of the entire investment structure.

The August 2026 issue of TEMPLARS Tax Transcripts examines developments in treaty policy, fiscal administration, and stamp duty adjudication as Nigeria continues to align administrative practice with its new tax statutes. Key updates include the signing of a Double Taxation Agreement between Nigeria and Hong Kong, the commencement of the Green Tax surcharge on imported high-engine vehicles, and the Accountant-General's directive to discontinue the 1% stamp duty deduction on payments to contractors, vendors