Africa Tax In Brief

AFRICA: Technical note on Global Minimum Tax Side-by-Side Package published by Africa Tax Administration Forum

On 6 February 2026, the Africa Tax Administration Forum (“ATAF”) published a Technical Note summarising changes to the Global Minimum Tax (“GMT”), referred to as a "Side-by-Side Package". The Note explains each of the components of the Side-by-Side Package and sets out ATAF's position on associated safe harbours: the Side-by-Side (“SbS”) safe harbour and ultimate parent entity (“UPE”) safe harbour.

The ATAF: 

• Notes that its members have the same imperative to act in response to the opportunity presented by the GMT. Without action, tax to which ATAF member countries are entitled will be collected by another country, either through an income inclusion rule or by a SbS country;
• Welcomes the protection for qualified domestic minimum top-up tax (“QDMTT”) and the confirmation that QDMTT jurisdictions would not be required to credit residence country taxes such as controlled foreign company taxes through a push down mechanism to source countries;
• Invited larger economies within its membership to consider requesting the SbS safe harbour or UPE safe harbour and encourages early action in this regard;
• Has consistently viewed the GMT as an opportunity for African countries to reassess and rationalise excessive or inefficient tax incentives. Accordingly, the expansion of incentives recognised under the GMT is not considered a preferred outcome from ATAF's perspective;
• Welcomes a substance-based income exclusion (substance cap). However, it actively advocated for a much lower number, not more than 2% of payroll cost or depreciation of tangible assets, as higher rates of the cap could potentially undermine the very objective of GMT; and
• Promises to undertake an impact assessment of the new rules and actively participate in the stock-take exercises of the effectiveness on the GMT for its members.

CEMAC: Community projects to be paused due to member states' retention of import tax

The Commission of the Economic and Monetary Community of Central Africa (“CEMAC”), which includes Cameroon, the Central African Republic, Chad, the Republic of the Congo, Gabon and Equatorial Guinea, has announced that it will pause community projects and missions until the collection of the community integration tax improves. The tax, primarily collected on imported goods, is intended to fund the regional body's collective activities and administrative functions. CEMAC complained that member states are retaining their import levies rather than transferring them to the Commission.

The Commission has urged member governments to reconsider their handling of the integration tax, suggesting that an independent collection mechanism might be necessary to ensure that these levies are secured for their intended regional purpose rather than being absorbed into national budgets.

BURKINA FASO: Certified electronic invoicing system launched

On 6 January 2026, the Directorate General of Taxes (“DGI”) has launched a certified electronic invoicing system as part of the ongoing modernisation of the tax administration framework. The main features of the certified electronic invoicing system include:

• Enabling the real-time transmission of invoicing data to the tax authorities;
• Improving the traceability of commercial transactions;
• Enhancing transparency in business operations; and
• Strengthening tax compliance and reducing opportunities for tax fraud.
• The use of the certified electronic invoicing system will become mandatory for taxpayers from 1 July 2026.

CABO VERDE: New e-invoicing requirements introduced

An e-invoicing mandate in Cabo Verde was introduced in 2020 by decree No. 79/20 as part of the digital transformation program in the country. The fatura eletrónica e-invoicing system was implemented in phases, starting on 2021 with a pilot phase, followed by a voluntary phase, and finally a mandatory phase, which concluded in 2022.

It requires: E-invoices and related tax documents to be issued in XML format; be digitally signed; and cleared by the tax authorities in real-time/near real-time before being exchanged with the buyer;

E-invoices to be issued using certified invoicing software or through the government's free manual e-invoicing platform designed for small taxpayers.

The 2026 State Budget Law proposal was approved by Parliament, introducing additional requirements with effect from 1 January 2026, including: 

• Mandatory electronic issuance: all invoices and tax-relevant documents must be issued electronically by all taxpayers; and
• QR code and Unique Document Identifier (“UDI”): all invoices and related tax documents must have a QR code and UDI.

CôTE D’IVOIRE: VAT treatment of rent from unfurnished buildings clarified

In an official note issued by the Directorate General of Taxes on 6 February 2026, the Ivorian tax authorities have clarified the VAT treatment applicable to rent derived from unfurnished buildings, confirming that such rental activity is civil in nature and remains outside the scope of VAT.

The clarification, which applies with immediate effect, confirms that:

• Rent amounts received from the leasing of unfurnished buildings are not subject to VAT, as such leasing activity is considered civil in nature and does not constitute a taxable commercial activity;
• Only rent amounts derived from furnished leases or from the leasing of buildings fitted out for industrial or commercial use and serving as premises for the exercise of a professional activity are subject to VAT by operation of law, as these leases qualify as commercial activities;
• The implementation of mandatory electronic invoicing does not affect the exclusion from the scope of VAT applicable to rent from unfurnished buildings. Accordingly, such rent remains subject to property tax; and
• The implementation of mandatory electronic invoicing does not affect the exclusion from the scope of VAT applicable to rent from unfurnished buildings. Accordingly, such rent remains subject to property tax.

CôTE D’IVOIRE: Finance Law 2026 adopted with limited changes from the draft Bill

The 2026 Finance Law was promulgated on 19 December 2025 and applies from 5 January 2026. Most provisions have been adopted as proposed by the Bill 2026 (*to learn more, please refer to previous Africa tax in brief), with only a limited number of differences, including:

• Aligning transfer pricing rules with the 2023 ECOWAS Directive, notably through:
  • explicitly incorporating the arm's length principle;
  • introducing documentation obligations;
  • clarifying dependency relationships; and
  • introducing penalties for non-compliance.
• Introducing quarterly payment obligations for taxpayers under the synthetic tax regime, replacing monthly instalments with four equal payments due on 31 March, 30 June, 30 September and 30 November; and
• Providing for a post-adoption reduction of the VAT rate to 9% for certain products and operations that had been moved to the standard 18% VAT rate. This adjustment was introduced by Ordinance No. 2026-03 of 7 January 2026, published on 16 January 2026 and effective from 17 January 2026.

CôTE D’IVOIRE: Exclusive use of electronic standardised invoices announced

Through an official notice published on 27 January 2026 on the Directorate General of Taxes' website, the Ivorian Tax Administration has confirmed the end of the exceptional use of physical standardised invoices and the mandatory transition to electronic standardised invoices (Factures Normalisées Electroniques, “FNE”).

The use of physical standardised invoices ended on 1 December 2025 for taxpayers under the standard and simplified tax regimes and on 11 December 2025 for taxpayers under the synthetic tax regime. For taxpayers subject to the state entrepreneur tax, the use of physical standardised invoices remains permitted until 13 February 2026 for transactions with other businesses or the state.

Registration on the FNE platform has become a mandatory condition for the issuance of a tax clearance certificate (Attestation de Régularité de situation fiscale, ARF). The Tax Administration has set 31 January 2026 as the final deadline, after which only electronic standardised invoices and receipts may be used. Failure to comply will result in penalties under the Tax Procedures Code.

Only electronic standardised invoices will be accepted to justify deductible expenses and to support the deduction of VAT on the acquisition of goods and services. Multi-department retail stores are required to attach electronic standardised receipts to cash register tickets to validate transactions for tax purposes.

ESWATINI: Mandatory VAT apportionment for mixed-use property developers announced

In a judgment delivered on 29 January 2026, the Revenue Appeals Tribunal has ruled that businesses making both taxable and exempt supplies must apportion input VAT in accordance with section 28(10) of the VAT Act 2011.

In the case at hand, a property developer engaged in both commercial and residential property leasing, had claimed a VAT refund. Following a VAT compliance audit by Eswatini Revenue Service (“ERS”) covering January to March 2024, the ERS reduced the refund based on the statutory VAT apportionment formula for "mixed supplies," which applies when a business makes both taxable and exempt supplies. Commercial property leasing is taxable at 15% VAT, while residential property leasing is generally exempt.

The central issue was whether a taxpayer making mixed taxable and exempt supplies can selectively exclude high-value input VAT invoices from the statutory apportionment calculation. The appellant argued that an invoice of SZL6.5-million related exclusively to the construction of a commercial shopping centre and was therefore fully deductible. It further contended that including the invoice in the apportionment calculation resulted in double taxation and violated the principle of VAT neutrality. The ERS countered that the VAT Act does not permit selective exclusion of invoices from apportionment once a taxpayer is making mixed supplies during a tax period.

The Tribunal held that, once mixed supplies are established, the formula must be applied to all input tax not exclusively attributable to exempt supplies. It further found that any alternative method approved under section 28(10) of the VAT Act must apply to the taxpayer's entire VAT accounting system and cannot be used to isolate particular high-value transactions. The Tribunal dismissed the appeal and confirmed the ERS assessment.

LIBERIA: Plan for 2026 carbon tax on international shipping denied

The Liberian Maritime Authority has issued a press release clarifying that the government does not impose, nor intends to impose, a carbon tax or carbon levy on international vessels calling at Liberian ports. The clarification dismisses recent media reports suggesting that the government planned to introduce a carbon levy on international shipping from 1 March 2026.

The government reaffirmed its commitment to internationally agreed frameworks for reducing greenhouse gas emissions from shipping, particularly those developed under the International Maritime Organisation It emphasized that it will not adopt unilateral national measures that could conflict with global frameworks.

LIBERIA: Order exempting Liberia Electricity Corporation from customs duty, goods and services tax issued

On 23 January 2026 the President issued Executive Order No. 157, granting the Liberia Electricity Corporation (“LEC”) exemptions from the payment of customs duties and goods and services tax (“GST”) on specified electricity sector goods, including equipment, materials and fuel used for electricity generation, transmission and distribution. The Order sets out, in Schedule A, a list of exempt goods, including:

• Fuels, lubricants and consumables, including crude petroleum oils, petroleum oils (such as heavy fuel oil, Light Fuel Oil and Automotive Gas Oil), fuel additives and lubricating preparations;
• Thermal power generation equipment, including turbines, engines and parts, boilers and steam Generators, compressors, pumps, fuel storage tanks and containers for liquefied or compressed gas;
• Renewable energy generation equipment, including solar photovoltaic panels, static converters and inverters, hydraulic turbines, electric generating sets and wind-powered generating sets;
• Battery energy storage systems, including lithium-ion batteries, power conversion systems and electronic control modules;
• Transmission, substations and grid interconnection equipment, including transformers, switchgear, control panels and supervisory control and data acquisition (SCADA) systems, electric conductors and cables, optical fibre cables, towers and poles, and electrical resistors;
• Metering and advanced metering infrastructure, including electricity meters, metering kiosks and cabinets, and data communication equipment;
• Specialised vehicles and construction equipment, including cranes, lifting machinery, utility vehicles and trucks; and
• Spare parts and major maintenance components, including generator, engine, turbine and transformer parts.

The Order addresses the rising fuel and operational costs faced by the LEC and aims to support the sustained provision of electricity to consumers at affordable and stable tariff levels.

LIBERIA: 2026 National Budget passed by the Legislature

The 2026 National Budget (*to learn more, please refer to previous Africa tax in brief), which was formally adopted by the Liberian Legislature on 19 December 2025, has been approved by the President on 26 January 2026.

The government is pursuing several reforms to strengthen revenue generation, including increasing the goods and services tax by 1%; expanding the tax base through enhanced compliance measures to curb tax evasion and updated tax rules; and implementing a VAT system by 2027.

MALAWI: Pilot phase for implementation of electronic invoicing system further extended

Through a public notice issued on 30 January 2026, the Malawi Revenue Authority has extended the pilot phase for the implementation of the electronic invoicing system ("EIS") from 1 February 2026 to 30 April 2026 (*to learn more, please refer to previous Africa tax in brief). With effect from 30 April 2026, electronic fiscal devices will not be accepted.

MALAWI: President assents to 2025 Tax Amendment Acts

On 20 December 2025, the President assented to the Taxation (Amendment) Act, 2025 and the VAT (Amendment) Act, 2025, adopting all proposals in the mid-year Budget review. Key amendments, which are effective from 31 December 2025, include:

• Introducing a minimum alternate tax (MAT) of 0.5% on turnover. The MAT is applicable on companies in a continuous loss position with turnover exceeding MWK5-billion and operating for more than three years;
• Reducing the supernormal profit tax threshold from MWK10-billion to MWK5-billion to be taxed at 40%;
• Revising the employment income tax rates;
• Removing the capital gains tax incentive for share disposals. capital gains tax will accordingly apply on all share disposals regardless of holding period;
• Introducing a money transfer levy of 0.05% on transactions exceeding MWK100 000 made through electronic systems operated by a bank or an e-money service provider. The levy is payable by the sender, while banks and e-money service providers act as collecting agents responsible for filing and remitting the collected levies;
• Increasing the withholding tax rate on gambling winnings from 10% to 15%; and
• Increasing the standard VAT rate from 16.5% to 17.5%.

MAURITIUS: Lists of reportable and participating jurisdictions for Automatic Exchange of Financial Account Information updated

On 9 February 2026, the Mauritius Revenue Authority (“MRA”) published updated lists of reportable and participating jurisdictions for the purpose of the automatic exchange of financial account information under the Common Reporting Standard Multilateral Competent Authority Agreement (“CRS MCAA”).

Fiji, Ivory Coast and Zimbabwe have been added to the updated list of reportable jurisdictions, while Nigeria, Thailand and Uganda have been added to the updated list of participating jurisdictions. The lists concern the relevant jurisdictions for the 2026 reporting year, in respect of 2025 reportable accounts.

MAURITIUS: Multilateral Competent Authority Agreement on Automatic Exchange of Information Pursuant to the Crypto-Asset Reporting Framework signed

On 12 December 2025, Mauritius signed the Multilateral Competent Authority Agreement on Automatic Exchange of Information Pursuant to the Crypto-Asset Reporting Framework (“CARF MCAA”). The CARF MCAA, which has been signed by 55 jurisdictions, allows for the automatic exchange of tax-relevant information on crypto-assets, consistent with the reporting and due diligence procedures set out in the Crypto-Asset Reporting Framework (CARF).

MAURITIUS: Addendum to the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Information

On 12 December 2025, Mauritius signed the Addendum to the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (2024) (Addendum to the CRS MCAA). The Addendum to the CRS MCAA adds new information items to be exchanged under the CRS MCAA, reflecting additional reporting requirements introduced in the 2023 update to the Common Reporting Standard.

As of the most recent OECD update, the Addendum to the CRS MCAA has been signed by 69 jurisdictions.

MAURITIUS: Revenue Tribunal Act replaces Assessment Review Committee

The MRA has announced on 13 January 2026 that the Revenue Tribunal Act (“RTA”) is now in force, establishing the Revenue Tribunal to replace the Assessment Review Committee (“ARC”) previously constituted under the MRA Act. The RTA was proclaimed on 22 December 2025 and came into force on 5 January 2025.

Under the RTA, any person aggrieved by a determination of the Director-General under an enactment specified in the Schedule to the RTA may appeal to the Revenue Tribunal. Appeals must be lodged with the Secretary of the Revenue Tribunal.

MOZAMBIQUE: Taxation of mobile wallet agents clarified

Following the recent amendments to the Personal Income Tax Code, approved by Law No. 11/2025 of 29 December, the Mozambique Tax Authority on 29 January 2026 issued Notice No. 03/2026 to clarify that the tax on the amount earned as commission paid by electronic money institutions (mobile wallet companies) to their agents will now be withheld at the rate of 10% (previously 20%).

MOZAMBIQUE: Special VAT Regularisation Notes for the extractive industry revoked

Through Decree 52/2025 dated 29 December 2025, the Council of Ministers has revoked the special VAT Regularisation Notes Regime in force for the mining and petroleum industry and approved a new specific VAT refund regime applicable to taxpayers operating in this industry with effect from 28 January 2026.

The approved new specific VAT refund regime establishes a procedure applicable to the reimbursement of VAT to entities in the extractive industry, including:

• Holders of mining research and prospecting licenses;
• Mining concessionaires;
• Entities covered by a concession agreement for oil exploration and production or instruments equivalent, including concessionaires, specific purpose entities under areas 1 and 4 of the Rovuma Basin, and designated operators; and
• Any other entities whose turnover derives from the entities above for at least 60%.

This new regime replaces the previous VAT Regularisation Notes regime and applies to the entities listed above, provided that they are in the research and prospecting or development phases involving an investment already made or to be made of at least USD25-million, or are in the production phase with more than 60% of their turnover destined for exports.

The special VAT refund regime also introduces:

• A 90-day deadline for the tacit approval of a VAT refund application by the tax authority, except in cases of suspension of the application;
• A 30-day deadline for taxpayers to refund the tax authority in cases whereby virtue of a tacit approval, it is further determined that the VAT refund paid was undue or paid in excess;
• An obligation for taxpayers to be registered with the tax authority and to renew registration on an annual basis;
• Specific response deadlines of 45 and 30 days respectively for the tax authority from the day of receipt of a claim or appeal filed by the taxpayers eligible for this regime; and
• A requirement for entities to have a clean compliance record for the last three fiscal years prior to application.

The Decree also amendment other provisions of the VAT Refund Regulation applicable to the taxpayers in general, including:

• Requiring more detail on supporting documentation for a VAT refund application. This should include, among others, a detailed statement of clients to whom goods or services were provided during the refund application period, including the zero-rated and exempt sales;
• Specifying that when suspending a VAT refund application, the tax authority must indicate in the notification the reason for the suspension and the respective legal basis, as well as the additional information and documentation to be provided by the taxpayer within a 30-day deadline; and
• Providing that diplomatic organisations can only apply for a VAT refund within 90 days from the invoice date that supports the refund request. Previously diplomatic organizations had a one-year deadline to apply for a VAT refund.

NIGERIA: e-Invoicing Implementation Timeline

The Nigeria Revenue Service (“NRS”) issued a public notice on 17 February 2026 regarding the implementation timeline for the phased rollout of the e-invoicing and Electronic Fiscal System regime, the Merchant Buyer Solution (“MBS”).

The MBS system went live on 1 August 2025, with all large taxpayers with annual turnover of at least NGN5-billion required to complete onboarding by 1 November 2025. The latest timeline includes that the implementation for large taxpayers has largely been completed, with a go-live review being conducted from January to March 2026 and compliance enforcement beginning in April 2026.

For medium taxpayers with annual turnover between NGN1-billion and NGN5-billion, stakeholder engagement began in January 2026, with a pilot rollout to begin in April 2026 and a go-live date of 1 July 2026. This is to be followed by a go-live review beginning in October 2026 and compliance enforcement beginning in January 2027.

For small taxpayers with annual turnover below NGN1-billion, stakeholder engagement is to begin in January 2027, with a pilot rollout to begin in April 2027 and a go-live date of 1 July 2027. This is to be followed by a go-live review beginning in October 2027 and compliance enforcement beginning in January 2028.

NIGERIA: Claims of 25% tax on building materials and VAT on banking services refuted by Tax Reforms Committee

Following rumours circulating in an online video, the NRS has issued an official statement on 15 February 2026 refuting claims that the Nigeria Tax Act, 2025 imposes a 25% tax on funds for building materials and other transactions, or that the new tax laws will take effect in 2027.

The NRS confirmed that the Act has already entered into effect and does not impose a 25% tax on construction funds, bank balances, or business expenses. Instead, the Act introduces provisions aimed at reducing housing costs, rent and real estate development expenses, including:

• VAT exemption for land and buildings;
• Input VAT credits for contractors on their assets and overhead costs;
• A reduced withholding tax rate of 2% on construction contracts;
• Mortgage interest relief for owner-occupied homes, allowing mortgage interest deductions of up to NGN8-million; and
• Tax exemptions for qualifying real estate investment trusts.

The NRS has also clarified on 15 January 2026 that Nigeria's new tax law does not introduce a new VAT on banking services, fees, commissions or electronic money transfers. The NRS emphasised that VAT has long applied to fees, commissions and charges for services rendered by banks and other financial institutions under Nigeria's established VAT regime. The Nigeria Tax Act neither introduced VAT on banking charges nor created any new VAT obligations for customers in relation to bank fees or electronic transfers.

NIGERIA: Road infrastructure tax credit scheme stopped by Federal Government

During a press briefing on 28 January 2026, the chairman of the NRS has announced discontinuation of the Road Infrastructure Development Tax Credit Scheme, which allowed companies to offset future corporate income tax liabilities against the cost of constructing or rehabilitating roads.

According to the NRS, the scheme fell outside its statutory mandate, which is confined to the assessment, collection and accounting of taxes, not the appropriation or execution of public expenditure. The NRS also indicated that it lacked the technical capacity to verify compliance with standards or assess the quality of roadworks completed before tax credits were issued.

NIGERIA: Gazetted Tax Laws reaffirmed by Senate

During the Senate's plenary session on 28 January 2026, the Senate President of Nigeria has reaffirmed that the recently enacted tax laws, which came into effect on 1 January 2026, remain unchanged as officially published in the Official Gazette of 26 June 2025, dismissing reports of any post-enactment modifications.

The clarification follows claims made by some legislators that multiple versions of the tax laws were circulating, creating confusion over which texts are authoritative. The Senate President maintained that all procedural steps were properly followed and that the gazetted texts are legally binding.

The National Assembly has published Certified True Copies of the following four recently enacted tax reform Acts following public concerns over alleged discrepancies between the laws passed by the legislature and the versions subsequently gazetted and circulated:

• Nigeria Tax Act, 2025;
• Nigeria Tax Administration Act, 2025;
• National Revenue Service (Establishment) Act, 2025; and
• Joint Revenue Board (Establishment) Act, 2025.

This follows an earlier press release by the Joint Revenue Board (JRB) refuting claims that the implementation of the new tax laws, which took effect on 1 January 2026, has been suspended. The High Court of the Federal Capital Territory (FCT), Abuja, in its ruling on 23 December 2025 in the case of Incorporated Trustees of African Initiative for Abuse of Public Trust v. Nigeria (FCT/HC/CV/5383/2025; Motion No: M/17240/2025), refused to halt the implementation of Nigeria's newly enacted tax laws.

TANZANIA: Court of Appeal rules VAT relief for licensed explorers is not automatic

In its judgment delivered on 14 November 2025, the Court of Appeal has dismissed an appeal and affirmed the additional VAT assessment in Geita Gold Mining Limited v. Commissioner General, Tanzania Revenue Authority (Civil Appeal No. 75 of 2024), holding that the VAT relief for explorers under the VAT Act is not automatically available to registered or licensed explorers in the absence of administrative procedures prescribed by the Minister. The Court of Appeal further held that taxable persons must account for imported services in their VAT returns, pursuant to the VAT (Imported Services) Regulations 2001.

In the case at hand, the Geita Gold Mining Limited (“GGML”), a registered company in Tanzania, was involved the exploration, prospecting and mining of gold in the Geita region and a holder of a Mining Development Agreement (“MDA”). Following a review of its VAT returns for 2012 and 2013, the Tanzania Revenue Authority (“TRA”) issued an additional VAT assessment of TZS4.2-billion on the grounds that GGML failed to declare various imported services in its VAT account and returns. GGML objected to the assessment, arguing that:

• These services qualified for the VAT relief under section 11 and item 8 of the Third Schedule, applicable to importations or supplies made to explorers for exclusive use in exploration activities; and
• This relief was automatic by virtue of its explorer status and that the imported services were therefore exempt from VAT.

The TRA argued that VAT relief was not automatic and required compliance with prescribed procedures. Not all imports or supplies to licensed explorers or prospectors qualified for relief. Consequently, the TRA confirmed the additional VAT assessment.

GGML challenged this before the Tax Revenue Appeals Board (“TRAB”), which upheld the TRA's position, ruling that approval was required to enjoy the relief. Correspondingly, the Tax Revenue Appeals Tribunal (“TAT”) dismissed the appeal and upheld the assessment. GGML, being dissatisfied, appealed to the Court of Appeal.

The Court of Appeal found and held that:

• Section 11 read together with item 8 of the Third Schedule grants special VAT relief to licensed explorers, but the relief is not automatic, as it is expressly subject to the limits and conditions in the Schedule and to "procedures prescribed by the Minister";
• The absence of ministerial procedures and administrative guidelines does not make the relief self-executing;
• The relief applies only where the following three cumulative factors are satisfied:
  • the person is a registered and licensed explorer or prospector;
  • the importation/supply is made by or to that person; and
  • the importation or supply must be used exclusively for exploration or prospecting activities;
• Imported services fall within the VAT accounting and reporting obligations under sections 3 and 26 of the VAT Act and regulations 3, 5 and 6 of the VAT (Imported Services) Regulations 2001, requiring declaration and reverse-charge accounting;
• The omission to declare imported services constitutes failure to make a proper return, entitling the Commissioner to raise an assessment under section 43; and
• The lower tribunals did not err in upholding TRA's assessment.

The Court of Appeal upheld the TAT's ruling, confirming that VAT relief under section 11 of the VAT Act, 1997 is not automatic. It is subject to statutory conditions and procedures prescribed by the Minister of Finance and the appellant having failed to comply with these requirements, it was therefore not entitled to the claimed relief. Additionally, the Court of Appeal held that imported services must be declared in VAT returns under section 26(1) of the Act. Failure to do so justified the TRA's additional VAT assessment for 2012–2013. Consequently, the appeal was dismissed in its entirety with costs.

ZAMBIA: Updated property transfer tax framework effective since 1 January 2026

Zambia’s Property Transfer Tax (“PTT”) (Amendment) Act, 2025 — in effect since 1 January 2026 — introduced significant refinements to the taxation of share transfers. PTT applies to both direct transfers of shares in Zambian-incorporated companies and indirect transfers, where shares in a foreign company are transferred and that company directly or indirectly owns 10% or more of a Zambian-incorporated company.

Significant amendments include a share transfer within a group of companies qualifying for nil-value treatment only if the transferor and transferee have been members of the same group for at least three years. Previously, group reorganisation relief required demonstrating that a transaction did not alter effective shareholding in the Zambian company. The amended law removes this test entirely. Relief is now governed solely by the three-year requirement, meaning ownership-neutral transactions may still attract PTT.

ZIMBABWE: Presumptive rental income tax on commercial property rentals introduced

On 5 February 2026 the Zimbabwe Revenue Authority (“ZIMRA”) issued a public notice announcing the introduction of a presumptive rental income tax with effect from 1 January 2026, pursuant to the Finance Act, 2025.

The 15% tax is charged on gross rental income derived from land or premises used for trade, business or occupational purposes. It is a final tax, with no deductions, credits, refunds or set-offs permitted. The tax applies to Zimbabwean residents, citizens in the diaspora, and non-resident property owners, with non-resident proprietors required to appoint a resident representative in Zimbabwe and comply with monthly filing and payment obligations.

The tax liability rests on registrable proprietors, including landlords, owners, lessees or sub-lessees who receive rental income directly or indirectly from tenants conducting business activities on the premises. Persons leasing land or buildings to another person carrying on business, trade or an occupation on such premises is required to register with ZIMRA, submit details of leased properties and tenants, and notify the authority of any changes to or cessation of the lease.

Registered and compliant proprietors under the self-assessment system as at 31 December 2025 are required to continue declaring rental income under the normal income tax rules. However, proprietors not registered by that date must register and pay presumptive rental income tax with effect from 1 January 2026. Any proprietor registered from that date onward will fall fully within the presumptive rental tax regime.

Monthly returns must be submitted by the 5^th day of the month following receipt of rental income, while payment of the tax is due by the 10^th day of that month. Non-compliance may result in recovery of outstanding tax and the imposition of penalties equal to 100% of the unpaid tax.

VAT continues to apply to taxable rentals at the prevailing rate of 15.5%. The tax also operates independently of PAYE, non-residents' tax and other withholding taxes, and landlords remain responsible for collecting informal traders' tax from eligible tenants.

ZIMBABWE: VAT return treatment clarified following rate increase

In a public notice issued on 26 January 2026, ZIMRA provided clarification on how VAT returns should be completed and submitted within the tax and revenue management system (TaRMS) following an increase in the rate from 15% to 15.5%, effective 1 January 2026.

ZIMBABWE: President assents to 2026 National Budget

On 29 December 2025, the President signed into law the Finance Act and the Appropriation Act, enacting the proposals made through the 2026 National Budget with effect from 1 January 2026 (*to learn more, please1 refer to previous Africa tax in brief).

Several tax amendments were approved and enacted, including those provided for in the National Budget, as well as retaining the gold royalty rate at 5% through the reversal of an earlier proposal to increase the rate to 10%, and withdrawing the proposal to introduce a cash withdrawal levy.

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