Africa Tax In Brief

ANGOLA: Public input invited on proposed Personal Income Tax Code

In order to simplify tax legislation, reduce compliance costs, broaden the tax base and promote tax justice, the General Tax Administration (AGT) has announced its intention to replace the existing multiple tax codes for different income types (employment income tax, capital gains tax, stamp duty, and property tax) with a single tax code covering all personal income - the proposed Personal Income Tax (Imposto sobre o Rendimento das Pessoas Singulares, IRPS) Code (IRPS Code). The IRPS Code proposes to group income into five categories:

• category A: income from dependent employment;
• category B: business and professional income;
• category C: capital income;
• category D: property income; and
• category E: asset increases.

The AGT has initiated a public consultation process to solicit feedback from a diverse array of stakeholders.

ANGOLA: E-invoicing to be introduced

The Angolan Government has announced the upcoming implementation of e-invoicing. Presidential Decree No. 71/25, published on 20 March 2025, establishes the Legal Framework for Tax Invoices, which applies to resident taxpayers in Angola and will take effect six months after its publication. It replaces the existing decree on the Legal Framework for Invoices and Equivalent Documents and incorporates electronic invoicing requirements.

Taxpayers subject to e-invoicing include those under the general and simplified VAT regimes, while those under the exclusion regime may opt in voluntarily. The Presidential Decree outlines the rules for issuing, rectifying, cancelling, and archiving electronic invoices issued and received electronically via invoicing software capable of real-time transmission to the General Tax Administration ("AGT").

Both e-invoice systems providers and the taxpayers using them must ensure operational and data integrity and maintain technical documentation. An AGT digital code must be applied to issued e-documents to guarantee authenticity and integrity and billing systems should report sales values on a bi-monthly basis. Taxpayers under the VAT exclusion regime and individuals with tax residency in Angola can issue invoices via the taxpayer portal. Upon AGT authorisation, taxpayers under the general and simplified VAT regimes may also issue invoices through this portal.

In September 2025, it will be required that all transactions exceeding KZ23-million (approximately EUR25 000) must be documented as an e-invoice or be issued on the taxpayer portal.

Once the Executive Decree outlining the technical specifications takes effect, during the following 12 months

• E-invoices will be mandatory for B2G transactions (excluding self-billing) and B2B transactions for large taxpayers; and
• Other taxpayers must issue invoices and tax-relevant documents using AGT-certified software.

After a further 12 months have passed since the Executive Decree outlining the technical specifications came into effect, all taxpayers in the scope must adopt e-invoicing.

BENIN: Taxation of hydrocarbon distribution activities clarified

The Director General of Taxes (Direction Générale des Impôts, DGI) has issued circular note No. 542/MEF/DC/SGM/DGI/DLC-DGE of 7 April 2025 (effective on the same date) clarifying the tax regime applicable to operators in the hydrocarbons sector in Benin, including authorised distributors and retailers or service stations.

The circular note addresses provisions relating to income tax, VAT, the retail tax regime and administrative matters.

BOTSWANA, CABO VERDE: Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (Cbc MCAA) signed

On 9 April 2025, Botswana and Cabo Verde joined the Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (2016) (Cbc MCAA), enabling the automatic exchange of country-by-country reports between countries, in line with the OECD's Base Erosion and Profit Shifting (BEPS) Action 13.

As at 14 April 2025, the Cbc MCAA has been signed by 112 jurisdictions.

BURKINA FASO, MALI AND NIGER: 0.5% levy on imports introduced

The Confederation of Sahel States (Alliance des États du Sahel, AES) has introduced a levy (Prélèvement Confédéral de l'AES, PC-AES) on products imported from countries other than Burkina Faso, Mali and Niger that are released for consumption within the Confederation's territory.

The tax, which is calculated and applied directly at the time of the customs declaration of imported goods, is levied at the rate of 0.5% of the customs value of goods, subject to listed exemptions.

The levy came into effect upon its signing by the President of the AES on 28 March 2025 and is based on the AES Founding Treaty adopted on 6 July 2024, and the Liptako-Gourma Charter of 16 September 2023.

CôTE d'IVOIRE: Convention and Protocol on Mutual Administrative Assistance in Tax Matters signed

On 23 April 2025, Ivory Coast became the 150^th jurisdiction to join the multilateral Convention on Mutual Administrative Assistance in Tax Matters, as amended by the 2010 protocol.

CôTE d'IVOIRE: Electronic standardised invoicing system implemented

The Tax Annexe of 2025, effective from 10 January 2025, mandates the issuance of electronic standardised invoices as part of the tax authority's Electronic Standardised Invoice System (FNE) and the Electronic Standardised Receipt System (RNE).

A structured roll-out plan provides for the following deadlines:

• 24 February 2025: Registration in the FNE platform opens for all taxpayer regimes in scope;
• 1 April 2025: Taxpayers covered by the Normal Real Tax Regime (RNI) must begin issuing e-invoices;
• 1 June 2025: Obligations extend to those covered by the Simplified Real Tax Regime (RSI);
• 1 August 2025: Compliance required for Microenterprise Regime (RME) taxpayers; and
• 1 September 2025: State Entrepreneur Tax (TEE) and Municipal Entrepreneur Tax (TCE) taxpayers must issue e-invoices.

Following the roll-out, all VAT-registered companies in the Ivory Coast must issue electronic standardised invoices or receipts for all transaction types (B2C, B2B and B2G), with certain limited exceptions.

Taxpayers can generate invoices using methods approved by the General Directorate of Taxes (DGI), including ERP integration via API, the FNE platform, the mobile FNE app, or payment terminals for receipts. Document validity must be ensured through certification with a QR code, the FNE visual, and serial numbering compliant with the DGI prescribed format.

DJIBOUTI: Finance Law 2025 published

Djibouti published the Finance Law for the 2025 State Budget (Law No. 150/AN/24/9ème L) in the Official Gazette on 29 January 2025. Significant tax measures, which are effective from 1 January 2025, include:

• Reintroducing the minimum lump-sum tax exemption for petroleum companies more than 50% held by the state or a public body (previously repealed by Finance Law for 2024);
• Repealing the following withholding tax exemptions:
  • exemption for dividend payments below DJF-10 million; and
  • exemption for remuneration paid to non-residents for providing services relating to financial or insurance transactions and paid by the insurance companies, banking establishments, and similar entities operating in the banking or insurance markets;
• Introducing a 0.2% tax on telegraphic, mobile money, and transfer agent transactions, with an exception for transactions below DJF1 000 and internal transfers between accounts or banks of the same holder;
• Introducing VAT on bank commissions, while other bank transactions are exempt; and
• Introducing an environmental protection contribution levy at a rate of DJF5 on imported or domestically produced plastic bottles or preforms intended for bottling mineral water or carbonated water with or without added sugar or other sweeteners.

EQUATORIAL GUINEA: New Tax Code introduced

Equatorial Guinea enacted Law No. 1/2024 in November 2024, which introduced a new Tax Code with effect from 1 January 2025. Significant amendments as per the New Tax Code include:

• Reducing the corporate income tax rate from 35% to 25%;
• Introducing a 1.5% minimum tax on turnover, payable twice a year by 15 July of the current year in respect of the period 1 January to 30 June and by 15 January of the following year in respect of 1 July to 31 December;
• Revising the personal income tax brackets with a top rate of 25% on annual income exceeding XAF20-million;
• Introducing a new withholding tax in the hydrocarbon sector at the rate of 3% for resident contractors and 10% for non-resident contractors and subcontractors; and
• Introducing a standard withholding tax of 10% on payments to non-residents, although a 15% rate is maintained for dividends paid to non-residents.

GHANA: Tax Amendment Bills 2025 assented to by the President

On 2 April 2025, the President assented to the following tax amendment Bills 2025, which were passed by the Parliament on 26 March 2025:

• the Income Tax (Amendment) Act 2025;
• the Electronic Transfer Levy (Repeal) Act 2025;
• the Emissions Levy (Repeal) Act 2025;
• the Value Added Tax (Amendment) Act 2025;
• the Special Import Levy (Amendment) Act 2025; and
• the Growth and Sustainability (Amendment) Act 2025.

The Acts are effective from 2 April 2025.

MALI: New levies on electronic transactions introduced

In order to finance the support fund for basic infrastructure and social development, the transitional President of Mali has introduced new levies on electronic transactions with effect from 10 February 2025 at the following rates:

• 10% on the amount of mobile phone credit top-ups and the amount of bills for telephone and internet subscriptions; and
• 1% on withdrawals made via mobile money.

Telecommunication operators are required to collect and pay the tax on a monthly basis.

MALI: Various tax changes introduced

With effect from 7 February 2025, Mali has introduced various amendments to its tax legislation, including:

• Introducing a special solidarity contribution on companies (Contribution Speciale de Solidarite, CSS), applicable to businesses subject to corporate income tax or industrial and commercial profits tax at a rate of 0.5% of gross turnover and subject to the same rules of assessment and liability as VAT;
• Introducing a special contribution on the consumption of alcohol (Contribution Spéciale sur la Consommation des Boissons Alcoolisées), calculated on the basis of volume in litres, with a fixed rate varying between F.CFA1 000 and F.CFA6 000 per litre, subject to certain exemptions. Producers and importers are legally liable for the contribution, which becomes due upon first delivery for local products or customs clearance for imports;
• Increasing the rate of tax on the use of an unrestricted telecommunication network (Taxe sur l'Accès au Réseau des Télécommunications Ouvert au Public (TARTOP)), applicable to holders of licenses to operate telecommunications networks open to the public, from 5% to 7%; and
• Adopting criminal penalties for non-compliance with the obligations set out in the OHADA Uniform Acts, particularly in terms of company management.

MAURITIUS: Assessment Review Committee allows taxpayers' claim for investment tax credit

On 15 April 2025, the Assessment Review Committee (ARC) ruled in favour of CDL Knits Ltd (CDL), allowing its claim for an investment tax credit (ITC) (ARC/IT/381-21 & ARC/IT/572-22).

CDL is an export-oriented textile company which undertakes the production and dyeing of knitted fabrics for sale. During the income years ended 30 June 2017 and 30 June 2018, the company claimed ITC on plant and machinery.

To claim ITC, a manufacturing company has to:

• Incur capital expenditure on new plant and machinery during the period 1 July 2016 to 30 June 2020; and
• The plant and machinery must be used in the manufacturing of goods.

The assets were imported in fragmented parts prior to 30 June 2016 and assembled and put into use after June 2016. Once the parts were assembled and tested, a commissioning certificate was issued. The imported parts were reported as work-in-progress in CDL's financial statements prior to commissioning.

The MRA disallowed the ITC claimed in respect of specific plant and machinery on the basis that capital expenditure was incurred on the plant and machinery prior to 30 June 2016, and raised assessments accordingly. Their argument was that the shipment date of each respective spare part was the date on which capital expenditure was incurred, as there was a transfer of ownership on that date.

CDL argued that the date on which the order was placed cannot be taken as the date of acquisition of the asset, as the asset has only been acquired for the production of gross income once it has been delivered and assembled.

The ARC applied a three-stage functional test to determine whether the asset constitutes plant, i.e.

1. Is the item stock in trade?
2. Is the item categorised as the business premises or part of the business premises?
3. Is the item used for carrying on the business (the business-use test)?

The ARC held that CDL is eligible for ITC on the specific plant and machinery on the basis that:

• The asset constitutes plant since the responses to (1) and (2) above are negative and the response to (3) above is positive;
• The spare parts are non-functional on their own and require assembly;
• CDL has incurred expenditure on plant and machinery only once the spare parts were assembled and commissioned; and
• The use of the plant only occurred after its assembly and commissioning, which was after 1 July 2016.

MOZAMBIQUE: 2025 National reconstruction tax rates approved

The Ministry of Economy and Finance of Mozambique has approved the national reconstruction tax (NRT) rates for 2025 through Ministerial Diploma no. 117/2024 of 12 December 2024.

NRT is imposed on individuals aged between 18 and 60 earning taxable income as defined by the Individual Income Tax Code (Código do Imposto sobre o Rendimento das Pessoas Singulares, IITC) 33/2007, who are residents in districts of the country that are not formal municipalities.

MOZAMBIQUE: New procedures for monthly reporting of VAT invoices issued

The Mozambique Directorate General of Taxation (DGI), through Notice no. /AT/DGI/2025 of 27 March 2025, has issued new procedures for the monthly reporting of invoices by VAT taxpayers. Under the new procedures:

• From May 2025, VAT taxpayers must submit on a monthly basis to the MTA a file with the data of the invoices issued in relation to their operations carried out in the previous month;
• The file must be extracted from the invoicing software in use by the taxpayer and duly certified by the MTA and further submitted through the MTA electronic declaration website (edeclaração.at.gov.mz);
• Companies that develop accounting and invoicing software in Mozambique should contact the MTA to obtain the requirements of the data structure of the standard audit file for tax (SAF-T) files for invoicing and the certification procedures of the respective programmes;
• The information in the file must include: the day and month of the transaction; the identification of the parties involved; the description of the goods; the unit and total values of the goods transferred, or services provided; and the VAT amount invoiced;
• Taxpayers with high volumes of monthly invoices may extract and send the above required information in a fractional manner, such as on a daily or weekly basis, while those with few invoices in the month are allowed to submit them in one complete file; and
• Taxpayers who fail to submit the aforementioned file are subject to legal penalties.

NIGERIA: Economic development incentive scheme to be introduced

The federal government has announced its plans to replace the Pioneer Status Incentive (PSI) scheme with the Economic Development Incentive (EDI) scheme, targeted at priority sectors, particularly companies operating in manufacturing, service delivery, and infrastructure.

The proposed EDI scheme will grant companies a 5% annual tax credit over five years, totalling 25% of the value of their qualifying investment, in addition to existing capital allowances. Unlike the PSI, the EDI is tied to capital deployment and introduces minimum investment thresholds to ensure only scalable and impactful projects qualify for the scheme.

NIGERIA: Pharmaceutical raw materials exempted from import duty and VAT

The President has issued an executive order granting a two-year exemption from import duty and VAT on critical raw materials needed for pharmaceutical production. The exemption covers active pharmaceutical ingredients, excipients, and other vital raw materials required for manufacturing essential medicines, long-lasting insecticidal Nets (LLINs), rapid diagnostic kits, reagents, and packaging materials.

Only manufacturers of pharmaceutical products with a tax identification number (TIN) and recognition from the Federal Ministry of Health and Social Welfare can benefit from the exemption.

RWANDA: Reward for final consumers requesting electronic billing machine VAT invoices introduced

A new Ministerial Order No. 002/25/10/TC of 16 April 2025 introduces changes in implementing the reward for final consumers requesting electronic billing machine (EBM) VAT invoices.

The changes introduced by the Order include a requirement for the final consumer who pays and requests an invoice but is denied or has his or her invoice fraudulently cancelled, to inform the tax administration through the VAT reward system and provide the following information: name, address and tax identification number of the trader; date of purchase; quantity and value of purchase; invoice issued by invalidated; and proof of payment.

The Order was published in the Official Gazette on 17 April 2025 and is effective from that date, repeals Ministerial Order No. 002/24/03/TC of 8 March 2024 determining the reward based on the VAT.

RWANDA: List of VAT-exempt financial and insurance services issued

Through the Ministerial Order No. 001/25/10/TC of 16 April 2025, which was published in the Official Gazette on 17 April 2025 and is effective from that date, the government has issued a list specifying financial and insurance services that are exempt from VAT.

UGANDA: 2025/26 Tax Amendment Bills published

The government has published the following tax amendment Bills for the financial year 2025/26:

• the Income Tax (Amendment) (No. 2) Bill 2025;
• the Value Added Tax (Amendment) Bill 2025;
• the Excise Duty (Amendment) (No. 2) Bill 2025;
• the Tax Procedures Code (Amendment) Bill 2025;
• the Hides and Skins (Export Duty) (Amendment) Bill 2025;
• the Stamp Duty (Amendment) Bill 2025; and
• the External Trade (Amendment) Bill 2025.

The Bills were published in the Gazette on 25 March 2025 and tabled before Parliament for the first reading on 27 March 2025. The Bills will take effect upon approval by the Parliament and assent by the President.

UGANDA: Public notice on Withholding tax exemption applications for 2025/2026 issued

The Uganda Revenue Authority has issued a public notice, announcing that applications for exemption from withholding tax by compliant taxpayers shall be received during the two-month period commencing on 1 April 2025 and ending on 31 May 2025.

The application is strictly online, and no physical applications shall be considered. Applicants shall be vetted based on a compliance checklist and only complaint taxpayers shall be granted the exemption. Once granted, the exemption shall be valid for a period of 12 months, from 1 July 2025 to 30 June 2026.

Exemption status is subject to automatic revocation if an entity or its associate(s) fail to regularly comply with its tax obligations during the financial year.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.