Africa Tax In Brief

AFRICA: Tax-to-GDP ratios increased in majority of countries on the continent in 2025

According to the OECD's Revenue Statistics in Africa 2025 report released in December 2025, tax revenues as a percentage of GDP have increased in 24 countries, decreased in 13 and remained unchanged in one. The average tax-to-GDP ratio for 38 African countries remained below other regions, which included an evaluation of The Gambia and Liberia for the first time.

For the second consecutive year, corporate income tax revenues were the main driver of overall tax revenue growth, rising by 0.3 percentage points in 2023. Taxes on goods and services also increased slightly, with VAT contributing 0.1 percentage points.

Taxes on goods and services remain the dominant source of revenue, accounting for 51.2% of total tax revenues in 2023, with VAT representing 26.6%. Income and profit taxes contributed 40%, split between personal income tax (16.5%) and corporate income tax (21.4%), according to the report.

AFRICA: Suggested approach to drafting Significant Economic Presence legislation published by African Tax Administration Forum

As part of its ongoing work in addressing the tax challenges arising from the digitalisation of the economy, the African Tax Administration Forum ("ATAF") has published its suggested approach to drafting Significant Economic Presence ("SEP") legislation on 1 November 2025. The key provisions of the suggested approach include:

• The taxable person that the legislation seeks to bring into the tax net;
• What it means to have a SEP in a country, including the use of materiality thresholds in defining a SEP;
• The digital services revenue in scope of a SEP;
• The rules for attributing revenues to a SEP;
• The mode of determining the taxable profits of a SEP using a deemed profits amount based on those attributed revenues; and
• The registration and filing requirements of taxable persons under a SEP.

The suggested approach emphasises that SEP legislation is an alternative to digital service tax ("DST") with the following differences:

• DST imposes tax on gross revenue while SEP charges tax on the profit or deemed profit of a non-resident; and
• SEP is usually designed as an income tax provision that would be within the scope of double tax agreements ("DTAs") whereas DST may be designed inside or outside the scope of income tax law and hence not be subject to DTAs.

ECOWAS: Air ticket taxes in member states abolished

In a statement issued on 10 December 2025, the Heads of State and Government of the Economic Community of West African States ("ECOWAS") have announced that all air ticket taxes in ECOWAS member states will be abolished effective 1 January 2026, and passenger and security charges will be reduced by 25% in line with the Supplementary Act on Aviation Charges, Taxes and Fees. Member states are required to amend national laws to ensure full implementation, while airlines are expected to pass on the cost reductions directly to passengers.

This measure is intended to reduce ticket prices and overall travel costs, boost airline operations, tourism, and trade.

ANGOLA: New e-Invoicing regime mandatory from 1 January 2026

Angola's Ministry of Finance issued a release confirming that the country's new electronic invoicing (e-invoicing) requirements are mandatory for large companies from 1 January 2026. This follows a transitional phase that commenced on 1 October 2025. Mandatory e-invoicing will be extended to all companies in 2027.

BENIN: Tax treaty with the United Arab Emirates enters into force

The Benin - United Arab Emirates Income Tax Treaty (2013) entered into force on 23 January 2025 and generally applies from that date for withholding and other taxes.

BOTSWANA: Tax amendment bills promulgated into law

The Value Added Tax ("VAT") (Amendment) Bill, No. 22 of 2025, has been promulgated into law following its publication on 31 October 2025 in the Official Gazette as the VAT (Amendment) Act, 2025. The Act will be effective from a date to be set by the Minister of Finance by Order published in the Gazette.

The VAT Amendment Act introduces significant amendments to the VAT system, most notably expanding the tax base to include VAT on remote services supplied by non-residents to residents of Botswana through electronic networks.

All new definitions, registration thresholds, reverse charge rules, residency indicators, obligations of non-resident suppliers, invoicing requirements, tax periods and penalty regimes as per the VAT Amendment Bill are retained.

CôTE D'IVOIRE: Tax Treaty with United Arab Emirates enters into force

The Ivory Coast - United Arab Emirates Income Tax Treaty (2021) entered into force on 14 December 2023 and generally applies from 1 January 2024.

The entry into force news was announced by the General Directorate of Taxes (DGI) of Ivory Coast, by way of internal memorandum (Note de service) No. 05140/MFB/DGI/DLCD-SDCFI/jtd/10-2025 of 23 October 2025.

DEMOCRATIC REPUBLIC OF THE CONGO: Yaoundé Declaration signed

On 22 November 2025, the Democratic Republic of the Congo ("DRC") became the 35^th African country to endorse the Yaoundé Declaration, thereby confirming its support for the regional initiative on tax transparency and the exchange of information for tax purposes, aimed at combating illicit financial flows through enhanced international tax cooperation.

The Yaoundé Declaration was originally signed on 15 November 2017 by four African countries during the tenth plenary meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes.

ETHIOPIA: 30% combined tax on petroleum products to be introduced

As part of the government's broader Homegrown Economic Reform Agenda, aimed at reducing the fiscal burden of longstanding fuel subsidies, the Ethiopian Petroleum Supply Enterprise (EPSE) began implementing the combined 30% tax on petroleum products (petrol and diesel) - announced earlier in the 2025/2026 Budget Statement - from December 2025. The collected tax will be remitted directly to the Ministry of Revenue.

ETHIOPIA: New tax incentives for exports, startups, and green energy projects proposed

The Ministry of Finance has invited public consultation on the recently released draft Council of Ministers Regulation on Investment Promotion which seeks to reform Ethiopia's current investment incentive regime. The draft Regulation, which proposes new tax incentives targeting exporters, startups, and green-energy projects, introduces the following key provisions:

• Scope of incentives: The Regulation generally permits the following types of incentives: (a) investment capital allowance; (b) exemption from the alternative minimum tax; (c) reduced income tax rates; (d) exemption from dividends tax; (e) exemption from capital gains tax; (f) deduction from income tax payable; and (g) customs duties incentives;
• Export incentives: Investors engaged in exports will no longer enjoy full income-tax exemptions. Instead, for a period of 10 years from the date of commencement of operations, developers operating outside special economic zones ("SEZs") will pay tax at a reduced rate of 10% on taxable profits, and those within SEZs at a rate of 5%. Following the 10-year period, the normal business profit tax rates under the Income Tax Proclamation will apply;
• Minimum capital requirements: SEZs must demonstrate a minimum investment of USD75-million and satisfy any additional requirements under the SEZ Proclamation No. 1322/2024;
• Dividend and minimum tax exemptions: Dividends distributed by SEZs to shareholders will be tax-exempt for five years and exempt from the alternative minimum tax for 10 years;
• Startups and green energy incentives:
  • startups will benefit from a 5% discount on taxable income for 10 years from the date they commence operations, and will enjoy a five-year dividend tax exemption;
  • startup developers will enjoy capital gains tax exemptions and may carry forward losses for up to three years. They will also be exempt from the alternative minimum tax for three years, provided they have incurred losses as investors in startups; and
  • green energy users (companies utilising at least 50% renewable energy) will pay tax at a rate of 15% on taxable income for a period of five years. A certificate from the Ministry of Water and Energy confirming compliance is required;
• Investment capital allowance: Companies involved in investment projects of at least USD1-billion will qualify for the investment capital allowance;
• Revised capital allowance rates: The Regulation updates capital allowance rates, with inter alia agricultural mechanisation tools and building equipment being subject to a 50% first-year allowance;
• Scientific research incentives: Businesses may deduct from their taxable income all expenses incurred on scientific or technological research directly related to production;
• Import incentives: Companies holding valid investment licenses will enjoy customs-duty and tax incentives when they import capital and construction equipment, raw materials, and spare parts;
• Transparency and monitoring: The Regulation strengthens reporting obligations. Implementing agencies such as the Ministry of Finance, Customs Commission, and Ethiopian Investment Commission must track incentives quarterly and beneficiaries are required to submit detailed quarterly reports outlining benefits received and progress achieved; and
• Accountability measures: The Ministry may claw back improperly granted or misused incentives. It must also publish annual summary reports of all incentives granted and integrate these into the national fiscal report presented to the parliament.

GABON: Tax treaty with Italy enters into force

The Gabon - Italy Income Tax Treaty (1999) entered into force on 19 December 2025 and generally applies from 1 January 2026 for withholding and other taxes.

GHANA: National VAT reward scheme to be launched in 2026

During an engagement with officials of the Large Taxpayer Office at VAT House in Accra on 10 December 2025, the Ministry of Finance has announced plans to introduce a national VAT reward scheme in 2026, aimed at strengthening taxpayer compliance and improving VAT collection.

Under the scheme, VAT receipts issued to tax-compliant consumers will be entered into a nationwide draw, offering participants the opportunity to win various rewards. The scheme is expected to encourage consumers to request VAT receipts for their purchases, thereby reducing leakages in the VAT system and reinforcing overall revenue performance.

GHANA: 2026 Budget presented to Parliament and various amendments implemented

On 13 November 2025 the Minister of Finance has presented the 2026 Budget Statement and Economic Policy to Parliament. The Budget proposes key tax reforms aimed at easing the VAT burden, increasing tax revenue, broadening the tax base, and advancing fairness in tax administration. Key proposed tax measures include:

• Abolishing the COVID-19 Health Recovery Levy;
• Ending the decoupling of the GETFund and NHIL levies from the VAT base, thereby permitting input tax deductions for both levies;
• Removing VAT on reconnaissance and prospecting activities in the mining sector;
• Reducing the effective VAT rate from 21.9% to 20%;
• Increasing the VAT registration threshold from GHS200 000 to GHS750 000;
• Extending VAT zero-rating on locally manufactured textiles;
• Deploying digital solutions to monitor and collect VAT on cross-border digital transactions by non-resident suppliers;
• Introducing fiscal electronic devices (FEDs) to strengthen VAT compliance and support real-time monitoring;
• Launching a VAT reward scheme to incentivise consumers to obtain VAT receipts;
• Fully rolling out the Unified Taxpayer Identification System; and
• Deploying the first phase of the Integrated Tax Administration System (ITAS) by December 2025.

The following tax bills were introduced to Parliament:

• VAT (Amendment) Bill;
• COVID-19 Health Recovery Levy (Repeal) Bill; and
• Ghana Education Trust Fund (GETFund) (Amendment) Bill.

The VAT Amendment Bill was passed into law as the VAT Act, 2025 (Act 1151) on 27 November 2025. In a public notice issued on 31 December 2025, the Ghana Revenue Authority ("GRA") has outlined major reforms introduced under the VAT Act, which came into effect on 1 January 2026, including:

• Increasing the VAT registration threshold for businesses dealing in goods from GHS200 000 to GHS750 000;
• Decoupling the National Health Insurance Levy (NHIL) and Ghana Education Trust Fund (GETFund) Levy to allow input tax credit claims;
• Treating the NHIL and GETFund levies as input tax deductions;
• Reducing the effective VAT rate to 20%; and
• Abolishing the VAT Flat Rate Scheme (VFRS) and replacing it with a unified VAT structure.

On 10 December 2025, the President signed into law the COVID-19 Health Recovery Levy Repeal Act, repealing the 1 % COVID-19 health recovery levy that applied to goods, services and imports since 2021 as a measure to finance government pandemic response and recovery measures. The Act came into effect on 1 January 2026.

GHANA: Modified taxation scheme for informal sector introduced

On 5 November 2025, the GRA has launched a Modified Taxation Scheme ("MTS") aimed at enhancing tax compliance among micro, small and medium-sized enterprises operating in the informal sector. The MTS, which requires individuals and businesses operating solely within Ghana with an annual income not exceeding GHS500 000 to pay a flat tax rate of 3% on annual income, seeks to:

• Simplify registration and payment procedures for informal sector taxpayers;
• Reduce bureaucracy and discretionary decisions in tax administration;
• Build trust and foster voluntary compliance among taxpayers; and
• Enhance domestic revenue mobilisation for national development.

GUINEA-BISSAU: New procedure for declaring VAT on import operations introduced

The General Directorate of Contributions and Taxes (Direção Geral das Contribuições e Impostos, DGCI) of Guinea-Bissau has issued Circular No. 23/GDGCI/2025, on 10 December 2025, requiring with immediate effect all importing companies subject to VAT to declare the VAT incurred on services related to customs clearance exclusively through the occasional revenue declaration (Declaração de Receitas Eventuais, DRE) model. The DRE model is a tax form required for reporting and paying taxes on non-regular, once-off or occasional income. It is submitted via the kontaktu online platform of the DGCI.

This measure seeks to enhance reliability of declared information, strengthen internal control mechanisms and standardise procedures, ensuring that all economic operators use a single, centralised and duly regulated process. The DGCI urges all companies to immediately adapt their internal procedures to ensure full compliance with the guidelines set out in the Circular.

KENYA: New standards levy on manufacturers enforced

On 4 November 2025, the Kenya Bureau of Standards (KEBS) has issued a public notice to all manufacturers enforcing the payment of the new standards levy introduced under the recently gazetted Standards Levy Order 2025 under Legal Notice No. 136 dated 8 August 2025.

The levy is set at 0.2% of monthly turnover from manufacturing activities, net of VAT, excise duty and applicable discounts. "Manufacturers" are defined to include any person who produce, process, treat, install, test, operate and use. Building, construction, textiles, mechanical engineering, electrical engineering, food, agriculture and chemical activities qualify as manufacturing activities under the Order.

Manufacturers with an annual turnover of at least KES5-million are required to make payments via the Kenya Revenue Authority ("KRA") iTax portal on or before the 20^th day of the month following the production month. The levy has an annual payment cap of KES4-million.

Failure to register or pay the levy constitutes an offence under the standards levy order, and non-payment attracts a penalty of 5% per month of the levy amount outstanding.

KENYA: Income and expenses declared in income tax returns to be digitally validated

The KRA has announced, through a public notice issued on 7 November 2025, that, effective 1 January 2026, it will digitally validate all income and expenses declared in individual and non-individual income tax returns. The validation will take place upon submission of the 2025 year of income returns and will be made against the:

• Tax invoice management system (TIMS/eTIMS) invoices;
• Withholding income tax gross amounts; and
• Import records from customs systems.

Taxpayers are therefore required to ensure that:

• All declared income and expenses are supported by valid electronic tax invoices transmitted with the buyer's personal identification number (PIN); and
• They obtain tax invoice management system (TIMS/eTIMS) schedules of their current annual income and expenses.

KENYA: Automated payment plan for settlement of tax liabilities introduced

The KRA has announced, through a public notice issued on 7 November 2025, the introduction of an automated payment plan ("APP") to allow eligible taxpayers to settle their outstanding tax liabilities, including principal tax, penalties and interest, through structured instalments. To qualify for the APP, taxpayers must:

• Hold a valid KRA personal identification number (PIN) and be fully compliant with iTax registration and profile updates;
• Have only confirmed tax liabilities that are not under active litigation or appeal;
• Demonstrate genuine inability or impracticality to pay the full tax liability in a single payment;
• Submit a proposed instalment schedule via iTax or other designated KRA portals, subject to system validation; and
• Ensure the instalment period is not more than six months.

Taxpayers must adhere to the agreed payment schedule to avoid termination and enforcement measures, including revocation of the tax compliance certificate and other legal recovery measures.

KENYA: High Court rules specified digital platform operators are subject to VAT

On 23 October 2025, the High Court has issued a ruling in the appeal case of Commissioner of Domestic Taxes v. Sendy Limited (Income Tax Appeal E137 of 2024), holding that a digital platform operator who exercises full control over the transactions between third-parties with customers is the principal supplier of services, not merely an intermediary, and is therefore liable to account for VAT on the full consideration received from customers.

This decision overturned the decision of the Tax Appeals Tribunal ("TAT") finding that Sendy Limited ("Sendy") was not a provider of transport services but simply a digital platform operator that merely connected third-party transporters with customers, thus the obligation to account for VAT rested with the person making the supply; in this case, the independent transporters.

Sendy operates a digital marketplace platform that connects independent third-party transporters to customers requiring transport or delivery services. Sendy earns income through a commission charged for the use of the platform. Following an audit of Sendy's 2015–2018 returns, the KRA issued additional assessments for corporate income tax and VAT based on discrepancies between the Sendy's declared income and banking records.

Sendy objected, and the KRA cancelled the corporate income tax but upheld the VAT assessment. Sendy appealed to the TAT, stating that it operates as a technology company that provides a digital marketplace, an online platform that connects independent third-party transporters with customers requiring delivery services, not a transport services provider. Therefore, its revenue was limited to the commission charged to the transporters for the use of the platform, for which it had duly accounted for and remitted VAT. The TAT, in its judgment, ruled in favour of Sendy, holding that it was not engaged in transport services but only operated a digital marketplace linking transporters and customers. The TAT held that VAT liability rests with the independent transporters who render the transport services.

Being aggrieved with the TAT judgment, the KRA appealed to the High Court, which found that:

• Section 5(1) of the VAT Act, 2013 imposes VAT on taxable supplies made in Kenya by registered persons, and while the VAT Act defines "supply of services," it does not expressly address multi-party digital transactions. In such cases, the courts must interpret the law according to economic and commercial reality, guided by persuasive foreign jurisprudence;
• VAT liability turns on whoever, in economic reality, controls and authorises the essential elements of the supply. In this case, Sendy exercised control over the entire transaction by determining the prices and billing process, dispatching drivers, issuing requests for payment (RFPs), collecting the full consideration in its own name, and remitting payments to drivers. These factors establish Sendy as the principal supplier of transport services, not as a mere intermediary for VAT purposes;
• Sendy's liability for VAT is on the full value of the consideration paid by the customer, and not merely on its commission; and
• Sendy was deemed, for VAT purposes, to have received the transport service from the third-party drivers and to have supplied it to the end customers.

KENYA: Draft Income Tax Regulations on advance pricing agreements and Pillar Two minimum top-up tax published

On 3 November 2025 the Commissioner General of the KRA has released, through a public notice, the draft Income Tax (Minimum Top-Up Tax) Regulations 2025, and the Income Tax (Advance Pricing Agreement ("APA") Regulations 2025. The KRA invited the public to provide their input and comments on the above regulations.

The draft Income Tax (Advance Pricing Agreement) Regulations 2025 are aimed at:

• Providing a framework for Kenyan taxpayers to negotiate APAs with the KRA regarding transfer pricing of related-party transactions;
• Outlining the procedures for pre-filing consultations, formal applications, negotiation, execution, renewal, and compliance reporting of APAs;
• Allowing unilateral, bilateral, or multilateral agreements depending on whether tax treaties exist, with each APA valid for up to a period of five years;
• Setting a requirement for applicants to pay a non-refundable fee of KES5-million for new applications and KES2.5-million for renewals, and file annual compliance reports; and
• Providing for revisions, cancellations, or revocations of APAs in cases of misrepresentation, non-compliance, or material changes in assumptions, while maintaining confidentiality of taxpayer information.

The draft Income Tax (Minimum Top-Up Tax) Regulations 2025 are aimed at:

• Operationalising Kenya's 15% global minimum tax under the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) Pillar Two;
• Requiring multinational enterprise ("MNE") groups with annual consolidated revenues of at least EU750-million to ensure that the combined effective tax rate in Kenya does not fall below 15%;
• Prescribing methods for computing net income, covered taxes, and the minimum top-up tax, along with substance-based income exclusions linked to employee costs and tangible assets;
• Providing safe harbour provisions, detailed record keeping and reporting obligations through the GloBE information return, and prescribing penalties for non-compliance; and
• Promoting tax transparency, preventing profit shifting, and ensuring fair taxation of MNEs operating in Kenya.

LIBERIA: Surcharges on imports extended

On 11 November 2025 the President issued Executive Order No. 156, renewing and replacing Executive Order No. 135 that retains an additional charge on certain imports, in light of the potential harm that may be caused to local manufacturers by the importation of large volumes of such goods.

The surcharges apply to specified products listed under corresponding Harmonised System codes in Appendix 1 of the Order, including flour, biscuits, eggs, soap, soft drinks, metal scrap, detergent powders, honey, plywood and square bars. The Order adjusts some surcharge rates but retains most unchanged.

LIBERIA: 2026 national Budget presented

The Minister of Finance and Development Planning has presented a draft 2026 national Budget to the National Legislature on 7 November 2025. The Budget is aimed at boosting tax revenue, broadening the tax base and enhancing fairness in tax collection. Significant proposed tax measures include:

• Introducing a 2% presumptive corporate income tax for major concession agreements, ensuring large operators contribute fairly to national development;
• Increasing the Goods and Services Tax from 12% to 13%, signalling a gradual move toward a full VAT framework; and
• Enhancing taxation of the digital economy to reduce revenue leakages and ensure fair contributions from cross-border digital transactions and global platforms.

LIBERIA: Bill to regulate tax incentives proposed

On 29 October 2025, the President has submitted to the House of Representatives a bill to amend the Liberia Revenue Code to establish a legal framework for tax incentives and expenditure management. The Bill aims to:

• Consolidate all existing and future tax incentives under a single, comprehensive framework;
• Address long-standing weaknesses in the existing framework for the approval, administration, and monitoring of tax incentives and expenditures;
• Establish a legal and institutional mechanism to record and evaluate all tax expenditures, ensuring that tax incentives align with national development priorities and deliver measurable economic benefits; and
• Strengthen fiscal governance by requiring transparency in the granting and review of tax incentives.

MALAWI: Medium-term Budget 2025/2026 presented

The Minister of Finance, Economic Planning and Decentralisation presented the 2025/2026 mid-year Budget Review Statement on 21 November 2025. Significant proposed tax amendments include:

• Reducing the threshold for application of additional tax of 10%, from MWK10-billion to MWK5-billion;
• Revising the employment income tax rates by raising the monthly exemption threshold from MWK150 000 to MWK170 000 and introducing a new rate of 40% for monthly incomes above MWK10-million;
• Introducing a transfer levy on mobile money transactions at a rate of 0.05%;
• Increasing the withholding tax rate on gambling winnings from 10% to 15%; and
• Increasing the standard VAT rate from 16.5% to 17.5%.

MALAWI: Transition period for implementation of electronic invoicing system extended

The Malawi Revenue Authority has, through a public notice issued on 4 November 2025, extended the transition period for the full implementation of the electronic invoicing system ("EIS") from 1 November 2025 to 1 February 2026. The extension is intended to facilitate a smoother migration from the existing electronic fiscal devices ("EFDs") to the new EIS platform. After the transition period, the EIS will replace the EFDs entirely and tax invoices generated from EFDs will no longer be valid for input VAT claims.

MALI: Budget 2026 presented to National Assembly

The Minister of Economy and Finance presented the 2026 Budget to the National Assembly on 9 December 2025. Significant proposed tax measures, which will take effect on 1 January 2026 once assented and published in the Official Gazette, include:

• Expanding the tax base to include the agricultural sector, informal economy, and taxation of digital activities;
• Amending the 2023 Mining Code to introduce new levies on surplus production and windfall profits for the mining sector, and reduce fiscal stability clause duration;
• Increasing excise duties on tobacco, alcoholic drinks, cola nut and coffee;
• Strengthening inter-agency data sharing and domestic exchange of information for multidisciplinary controls;
• Expanding digital procedures for tax filing and payment to include issuance of receipts and electronic tax clearance certificates and introducing electronic invoicing;
• Using the customs automated data system (ASYVAL) module for customs valuation and risk management;
• Deploying the integrated document control management system (Système Intégré de Gestion du Contrôle Documentaire, SIGECDO) for document-based risk control;
• Implementing new provisions on VAT credit management; and
• Rolling out the new tax management information system;

MAURITANIA: 2026 Draft Finance Law published

The Ministry of Finance has published the draft Finance Law for 2026 on 5 November 2025. The draft Law's main fiscal reforms are designed to modernise the tax system, diversify public financing sources, and align national policy with key economic, social and environmental objectives. Significant tax measures include:

• Introducing a tax on electronic transactions ("TTE") applicable to mobile money services (payment or transfer via mobile phone); electronic wallets and electronic payment applications; approved electronic fund transfer platforms; and commissions and other remuneration received by authorised agents for cash deposits related to the above operations where the operator is established in Mauritania. The tax rate is 0.1% on the gross amount of electronic payment or transfer transactions and 10% on commissions and other remuneration received by agents for cash deposit services. The TTE is collected at the source by the electronic service operator, which must remit the collected tax to the tax collector (Receveur des impôts) no later than the 15^th of the month following the month in which the transactions occurred;
• Increasing the existing tax on financial operations for specific electronic wallet transactions (commissions received on intrabank/interbank transfers, cash withdrawals, and state bill payments, where these operations are conducted via electronic wallets) to 20% to ensure fiscal neutrality across different financial platforms. The standard rate of 16% remains for other operations;
• Increasing the rate for climate contribution as part of a planned gradual rise. For 2026, the rate is set at MRU800 (USD20) per tonne of CO2 emitted, with the amount to be gradually increased to MRU2 000 (USD50) per tonne in the future. A compensatory downward adjustment of excise duties on petroleum products is simultaneously enacted; and
• Introducing a 16% VAT on smartphones while formally exempting basic utility phones from this tax.

MAURITIUS: Supreme Court rejects substance over form in inter-group leasing

In its judgement delivered on 28 October 2025, the Supreme court of Mauritius in the case of The Director General, Mauritius Revenue Authority v. The Assessment Review Committee & Noodle Express Ltd (2025 SCJ 498) has overturned a decision by the Assessment Review Committee ("ARC"), reaffirming the principle that taxation statutes – specifically the VAT Act – must be interpreted and applied strictly, leaving no room for the common law "substance over form" doctrine when statutory conditions are clear and unambiguous.

The case centred on whether a subsidiary company could claim an input VAT credit on rent paid by its holding company when the VAT invoice was issued solely in the holding company's name, despite the subsidiary being the actual occupier of the premises. Noodle Express Ltd ("Noodle Express"), a subsidiary of Hyvec Food Ltd ("HFL"), submitted a VAT input claim for rent paid on food court outlets leased by HFL but occupied by Noodle Express. Although HFL paid the rent and received VAT invoices in its name, Noodle Express sought to claim input VAT on the basis that it was the actual occupant of the premises.

The Mauritius Revenue Authority ("MRA") disallowed the claim, citing non-compliance with section 21(5)(a) of the VAT Act, which requires VAT invoices to be issued by suppliers legally authorised to charge VAT and made available for examination. The MRA issued an assessment including additional VAT, penalties and interest.

The ARC ruled in favour of Noodle Express. It adopted a "substance over form" approach, reasoning that although the VAT invoices for rent were issued in the name of HFL, the premises were actually occupied and used by Noodle Express. The ARC emphasised the practical realities of business operations and relied on the UK case Ashtons Legal v. HMRC [2022 UKFTT 00422 (TC)], which supports considering the substance of transactions rather than strict legal formalities. Based on this reasoning, the ARC concluded that Noodle Express was entitled to claim the input VAT credit on the rent paid by HFL for the outlets it occupied.

However, the Supreme Court ruled that the ARC had erred in law by allowing Noodle Express to claim input VAT on rent paid by its holding company, HFL, for premises occupied by Noodle Express. The Court emphasised that under sections 20(1) and 21(5) of the VAT Act, a valid VAT invoice must be issued to the person claiming the input tax credit, and in this case, the invoices were addressed to HFL, not Noodle Express. It found that the ARC wrongly applied the doctrine of "substance over form" and relied on the UK case Ashtons Legal v. HMRC, which was distinguishable because the facts differed significantly.

The Supreme Court allowed the MRA's appeal and remitted the case to the ARC for reconsideration in line with the strict statutory requirements. The decision reinforces the principle that VAT input claims must strictly comply with statutory provisions and cannot be justified solely on commercial substance or group arrangements.

MAURITIUS: Deadline set for Tax Arrears Settlement Scheme applications

The MRA announced in a communique dated 5 November 2025 that applications for the Tax Arrears Settlement Scheme ("TASS") 2025 must be submitted by 1 December 2025.

The TASS - a measure designed to help taxpayers regularise outstanding tax and contribution arrears while benefiting from full waiver of penalties, interest - is available to taxpayers with arrears outstanding as at 30 June 2025 arising from assessments or returns submitted under the following legislation:

• Income Tax Act;
• Value Added Tax Act;
• Gambling Regulatory Authority Act; and
• Social Contribution and Social Benefits Act 2021.

To receive a complete waiver of penalties, interest and surcharges included in the arrears, taxpayers must:

• Adhere to the set deadline of making the application;
• Settle the full amount of arrears by 31 March 2026; and
• Make their application electronically through the MRA website.

MAURITIUS: Tax Dispute Settlement Scheme launched

The MRA has, through a communique dated 5 November 2025, officially rolled out the Tax Dispute Settlement Scheme ("TDSS") 2025, a strategic initiative under the Finance Act, 2025 aimed at encouraging voluntary tax compliance and resolving long-standing disputes.

The TDSS offers taxpayers the opportunity to settle assessments that were under dispute before the ARC, the Supreme Court, or the Judicial Committee of the Privy Council, provided those proceedings were pending as of 5 June 2025. A full waiver of penalties and interest will be granted for the disputed assessments, subject to the following conditions:

• Taxpayers must submit an electronic application via the MRA website no later than 31 December 2025;
• The legal action that led to the dispute must be withdrawn prior to the application; and
• The outstanding tax must be paid in full by 31 March 2026.

MAURITIUS: Cabinet authorises signing of CARF MCAA and Addendum to CRS MCAA

On 7 November 2025, the Mauritian Cabinet authorised the signing of the Multilateral Competent Authority Agreement on Automatic Exchange of Information Pursuant to the Crypto-Asset Reporting Framework ("CARF MCAA") and the Addendum to the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (2024) ("Addendum to the CRS MCAA").

The CARF MCAA 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"). The CARF and the CARF MCAA are OECD initiatives aimed at addressing the growing crypto-asset market to ensure that tax transparency standards are maintained.

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. These updates aim to ensure the CRS remains effective in addressing international tax compliance challenges.

MAURITIUS: Fair Share Contribution compliance requirements for companies clarified

On 31 October 2025, the MRA has issued a communique informing taxpayers of the compliance criteria for the Fair Share Contribution ("FSC"). Companies liable for the FSC are those with annual supplies exceeding MUR24-million or those that are required to register under the VAT Act and have a chargeable income exceeding MUR24-million in an accounting year for income derived between 1 July 2025 and 30 June 2028.

Companies are required to pay FSC at a rate of 2% of chargeable income taxed at 3% and 5% of chargeable income taxed at 15%. Banks are subject to the FSC at a rate of 5% of chargeable income, with an additional 2.5% being levied on income from transactions with residents other than global business entities.

Every company liable to FSC must submit an electronic FSC statement and pay the contribution quarterly except for the final quarter, which is due within six months after the accounting year end. Companies with chargeable income exceeding MUR24-million for the 2024/2025 year of assessment to submit their first FSC statement between October 2025 and March 2026, depending on their accounting year-end.

MAURITIUS: Compliance procedures, deadlines for filing Qualified Domestic Minimum Top-Up Tax returns published

On 29 October 2025, the MRA has issued a communiqué informing taxpayers of the compliance procedures and deadlines for filing the Qualified Domestic Minimum Top-up Tax ("QDMTT") returns. The communiqué provides that:

• The QDMTT applies with effect from the year of assessment commencing on 1 July 2025 to resident companies that are part of an in-scope multinational enterprise ("MNE") group with a fiscal year ending on or after 1 January 2025;
• All affected companies are required to file their QDMTT returns and pay any tax due within 15 months after the end of the MNE group's fiscal year;
• Each resident entity forming part of an in-scope group must notify the MRA, within six months of the end of the group's fiscal year, of the designated Mauritian-resident person responsible for filing and payment;
• "Fiscal year" means an accounting period with respect to which the ultimate parent entity of the MNE group prepares its financial statements;
• For all notifications that are already due, the deadline has been extended to 30 November 2025. All in-scope companies are urged to comply with this new deadline. Notifications can be submitted through the MRA's online facility at mra.mu; and
• Companies must continue to file their regular income tax returns and pay tax within six months after the end of their accounting year.

MOZAMBIQUE: VAT refund regulation amended

Decree No. 52/2025 of 29 December was recently approved by the Council of Ministers, amending the VAT Refund Regulation, originally approved by Decree No. 78/2017, of 28 December and amended by Decree No. 30/2022, of 23 June. Significant amendments include:

• Requiring additional supporting documentation;
• Requiring that supporting documents accompanying the VAT refund request must signed, stamped and submitted either manually or via electronic means approved by the Tax Authority;
• Determining that a refund request may be rejected if the taxpayer has an outstanding liability or if irregularities are identified during the analysis of the request, with an amount equal or greater than the requested refund; and
• Revoking the Regularisation Notes Regime applicable to entities in the mining and petroleum sectors, and subjecting such entities to a special VAT refund regime.

MOZAMBIQUE: Draft Tax Laws approved by Council of Ministers

On 2 December 2025, the Council of Ministers has approved the draft Tax Laws amending the:

• Preliminary Instructions of the Customs Tariff Code;
• Code of Simplified Tax for Small Taxpayers;
• Excise Tax Code;
• Personal Income Tax Code; and
• Corporate Income Tax Code.

The Tax Laws will enter into force once they are approved by the parliament and published in the official Gazette. The Government also considered and approved:

• Amendments to the VAT Refund Regulation introducing a Special VAT Refund Regime for mining and petroleum sectors; and
• Ratification of bilateral agreements with Tanzania and Zambia for one-stop border posts.

MOZAMBIQUE: Protocol to tax treaty with Portugal signed

On 9 December 2025, Mozambique and Portugal signed an amending protocol to update the Mozambique - Portugal Income Tax Treaty (1991), as amended by the 2008 protocol, in Porto.

NAMIBIA: Submission of income tax returns relating to carry-forward of losses extended

On 31 October 2025, the Namibia Revenue Agency ("NamRA") has, through a public notice, extended the deadline to submit income tax returns by taxpayers affected by the implementation of the limitation of carry-forward losses under the amended section 21 of Income Tax Act, to 31 March 2026. The amended section 21 concerns taxpayers with assessed losses exceeding NAD1-million or 80% of the amount of taxable income determined, whichever is greater, from any prior year.

The extension applies to returns originally due between 31 July 2025 and 28 February 2026 giving affected taxpayers additional time to ensure compliance with the law.

NAMIBIA: High Court nullifies customs deferment

In its judgment delivered on 7 October 2025, the High Court of Namibia (Main Division, Windhoek), in the appeal case of Minister of Finance & Others v. Jack's Trading (Pty) Ltd (HC-MD-CIV-ACT-OTH-2023/02142) ([2025] NAHCMD 617, 7 October 2025, has ordered a local trading company, Jacks Trading (Pty) Ltd, to pay NAD49.3-million in outstanding customs duties on imported Portland cement.

The Court's decision is based on the finding that the Commissioner of Customs and Excise acted beyond their legal power by allegedly granting the importer an indefinite blanket deferment of customs duty payments over a five-year period (2012–2017). The Court reiterated the principle that the liability for customs duty is fixed upon importation, irrespective of any administrative arrangements for the deferred payment of that duty.

NAMIBIA: 2025/26 Mid-year Budget Review delivered

On 21 October 2025, the Minister of Finance has delivered Namibia's 2025/26 mid-year Budget Review. Significant proposed tax measures include:

• Reducing the corporate tax rate from 30% to 28% for all non-mining companies;
• Introducing a reduced corporate tax rate of 20% for non-mining micro, small and medium enterprises and special economic zone enterprises (SEZs);
• Deleting and replacing the definition of "dividend" under section 16 of the Income Tax Act with a provision exempting grants received from central government by state-owned enterprises;
• Taxing dividend income from preference shares;
• Introducing 10% withholding tax on dividends paid to natural persons and the estates of deceased persons;
• Aligning taxable income rules for long-term insurance companies;
• Increasing the minimum commutable amount for retirement benefits from NAD50 000 to NAD375 000;
• Imposing a cap amount of NAD400 000 on the annual housing benefit eligible for the one-third exemption under PAYE; and
• Enhancing the powers of NamRA to freeze the bank accounts of defaulting taxpayers and appoint agents to recover outstanding taxes.

The Income Tax Amendment Bill, 2025 has been presented for legislative consideration and is anticipated to be passed into law by the end of the financial year.

NIGER: Finance Law 2026 adopted by ordinance

On 31 December 2025, the Council of Ministers has adopted, by ordinance, the Finance Law for the 2026 Budget year (Finance Law 2026). Finance Law 2026 will be published in the Official Gazette and executed as the law of the State.

NIGER: Scope of Solidarity Fund contributions expanded

Through publication in the Journal Officiel on 13 November 2025, the Council of Ministers has adopted Ordinance N°2025-3 of 22 October 2025 which expands the scope of the Solidarity Fund for the Safeguarding of the Homeland (Fonds de Solidarité Pour La Sauvegarde De La Partie, ("FSSP")) and broadens its revenue base by introducing:

• A levy of 3% to 12% on the customs value of imported luxury consumer goods;
• A 4% levy on the value of listed exported agricultural, livestock and fishery products;
• A levy on each authorisation, license or certificate issued by the Single Window for foreign trade;
• A 15% levy on investment income of public enterprises and mixed-economy companies;
• A 1% to 2% levy on the turnover of major taxpayers in strategic sectors;
• A 1% levy on monthly net salaries of public, semi-public and private sector employees, with additional deductions on certain benefits for high-ranking officials;
• A 1% charge on monthly bills for postpaid mobile, lottery and internet services;
• A 10% levy on specific national funds, including the Universal Access Fund, the Mining Fund and intervention funds of financial administrations;
• A monthly contribution from NGOs and associations ranging from XOF10 000 to XOF100 000, depending on their size;
• A 3% levy on the rent of buildings leased by the State, its agencies, development projects, private companies and NGOs; and
• A 0.5% levy on the pre-tax amount of public procurement contracts.

Entities and individuals subject to the above levies benefit from several tax incentives introduced under article 4 of the Ordinance. The Ordinance expressly excludes from its scope privileges and exemptions granted to diplomatic and consular missions, United Nations bodies and institutions, and under the Geneva Conventions and beneficiaries of certain special regimes.

The Ordinance repeals and replaces Ordinance No. 2023-13 of 11 October 2023, which originally established the FSSP. The new ordinance broadens the fund's revenue base to secure additional financing for national defence and social support initiatives.

NIGERIA: Application of new Tax Laws to airlines clarified

In a LinkedIn post published on 30 December 2025, the Presidential Fiscal Policy and Tax Reforms Committee has clarified how Nigeria's recently enacted tax laws will apply to the aviation sector, responding to concerns raised by airline operators ahead of the laws scheduled commencement on 1 January 2026.

According to the Committee:

• Airlines will operate under a VAT-neutral regime that permits the recovery of input VAT on goods and services used in airline operations, including aircraft and aircraft-related imports, locally acquired assets, consumables, and other operational expenditure;
• Excess VAT credits may be refunded within 30 days or offset against other tax liabilities, subject to applicable administrative procedures;
• The 10% withholding tax previously imposed on aircraft lease payments has been suspended under the new framework. Replacement rates are to be prescribed by regulation and could be lower than the previous rate or set at zero;
• Existing import duty exemptions for commercial aircraft, engines, and spare parts will remain in force and will not be affected by the tax reforms; and
• The proposed reduction in the corporate income tax rate from 30% to 25%, combined with the harmonisation of profit-based levies — including the Tertiary Education Tax and statutory levies administered by the National Agency for Science and Engineering Infrastructure, the National Information Technology Development Agency, and the Nigeria Police — should reduce compliance complexity and the overall effective tax burden for airline operators.

NIGERIA: Federal Inland Revenue Service confirms smooth transition to Nigerian Revenue Service

In a LinkedIn post on 29 December 2025, the Federal Inland Revenue Service ("FIRS"), through its published responses to Frequently Asked Questions (FAQs), has addressed key concerns about its ongoing transition to the Nigeria Revenue Service ("NRS"), ahead of the statutory handover on 1 January 2026. The post confirms that:

• The NRS is the successor institution to the FIRS, established to modernise Nigeria's domestic revenue administration, strengthen governance, expand digitalisation, and improve operational efficiency;
• The NRS will coordinate with ministries, departments, and agencies (MDAs), state governments, and other public institutions to ensure effective revenue administration;
• Taxpayers should expect improved service delivery, more reliable and upgraded digital platforms, and enhanced guidance through public notices and communications;
• All existing taxpayer registrations, Tax Identification Numbers (TINs), and records issued under the FIRS regime will remain valid and will migrate seamlessly to the NRS systems;
• Existing tax collection, remittance, and reporting processes will continue to apply at the point of transition. Any system or process enhancements will be introduced gradually and communicated in advance; and
• All current system integrations and payment platforms will remain operational, subject to controlled upgrades, cybersecurity safeguards, and system optimisation.

NIGERIA: 1 January 2026 confirmed as commencement date of new Tax Laws

In a press release on 30 December 2025 Nigeria's President has confirmed that the country's newly enacted Tax Laws (Nigeria Tax Act 2025 and Nigeria Tax Administration Act 2025) will commence as scheduled on 1 January 2026 as originally planned. The new Tax Laws, as well as those that already took effect on 26 June 2025 — Nigeria Revenue Service (Establishment) 2025 and Joint Revenue Board (Establishment) Act 2025 — will proceed without delay.

NIGERIA: FIRS confirms National Identification Number serves as Tax Identification Number for individuals

In a public sensitisation video circulated by the President's Special Assistant on Social Media on 23 December 2025, the FIRS has announced that the national identification number (NIN) will serve as the tax identification number (TIN) for individual taxpayers under the new tax administration framework. For companies and other registered business entities, their corporate affairs commission (CAC) registration number will serve as their TIN.

The JRB has also issued a press release clarifying that the possession or use of a tax identification number (Tax ID) will not result in any deductions from bank accounts. It also stated that the introduction of the new tax regime on 1 January 2026 will not impose restrictions on bank accounts or financial transactions.

NIGERIA: Joint Revenue Board addresses transition from Joint Tax Board

In a communiqué issued on 10 December 2025, the Joint Revenue Board ("JRB") has addressed issues relating to its transition from the Joint Tax Board to the Joint Revenue Board, as well as the implications for national and sub-national revenue administration.

The JRB reiterated its prohibition of non-state actors from collecting taxes, levies, rates, or charges. It affirmed the ban on roadside tax collection, tax checkpoints, and the use of road stickers for tax enforcement. It also called on the office of the National Security Adviser, the Nigeria Police Force, and other relevant security agencies to take immediate steps to eliminate illegal roadblocks and unauthorised tax collection activities nationwide.

The JRB further urged state tax authorities to expedite the passage of the Harmonized Taxes and Levies (Approved List for Collection) Bill into law to ensure uniform application of taxes and levies at the sub-national level, in line with ongoing tax reforms.

NIGERIA: Tax Appeal Tribunal rules that share purchase agreements are subject to stamp duties

In its decision of 28 November 2025 in the case of Oando Oil Limited v. FIRS (Appeal No. TAT/LZ/SD/030/2024) the Tax Appeal Tribunal, Lagos Zone, has ruled that share-purchase agreements are subject to stamp duties.

The Tribunal held that stamp duties apply to the acquisition and purchase of shares and, in the case at hand, the instruments in question were share-purchase contracts, not mere share transfers – and therefore did not fall within the statutory exemption for share transfers.

The Tribunal upheld the FIRS's assessment in full, including penalties and accrued interest, and ordered Oando to pay 10% per annum interest on the unpaid duty until full liquidation.

NIGERIA: Implementation of 15% import duty on petrol and diesel deferred to 2026

Following the President's approval of a proposal submitted by the FIRS on 7 November 2025, the government has approved the deferment of the 15% ad-valorem import duty on petrol and diesel imports, which had initially been scheduled for immediate implementation on 21 October 2025, to the first quarter of 2026.

NIGERIA: Application of capital gains tax on share transactions confirmed by Presidential Tax Reforms Committee

Through a post on LinkedIn on 11 November 2025, the Presidential Fiscal Policy and Tax Reforms Committee has released a statement entitled "What You Need to Know About the New Capital Gains Tax Rules and Capital Market Investment in Shares". The purpose of the post is to clarify the new capital gains tax ("CGT") rules on share disposals, which are effective from 1 January 2026. The statement clarifies that:

• New CGT rate: the previous flat rate of 10% is replaced by progressive income tax rates ranging from 0% to 30%, depending on the investor's income level. The maximum rate of 30% will be reduced to 25% following broader corporate tax reforms;
• Allowable deductions: investors may now deduct a wider range of legitimate costs, including capital losses, brokerage fees, regulatory levies, margin interest, and realized foreign-exchange losses, provided that these costs are incidental to the investment;
• CGT exemptions will apply to:
  • disposals within 12 months where total sales proceeds do not exceed NGN150-million and total gains do not exceed NGN10-million;
  • reinvestments of proceeds into Nigerian shares within the same period;
  • gains repatriated through Central Bank-authorised channels;
  • institutional investors such as pension funds, REITs, NGOs, and small companies with turnover not exceeding NGN100-million and fixed assets below NGN250-million;
  • gains from investments in a labelled startup by venture capitalists or private equity funds, accelerators, or incubators; and
  • mergers, acquisitions, or internal restructurings;
• Base cost: for existing investments, the cost base will be reset to the higher of the actual acquisition cost and the closing market price as of 31 December 2025;
• Registration and administration: resident investors are to register for tax and file returns with the relevant tax authorities - individuals with their state of residence and companies with the NRS. Non-resident investors may pay any applicable CGT to the NRS or through authorized agents. All CGT liabilities are payable in Naira. Non-resident investors that earn only passive income are not required to register or obtain a Tax ID;
• CGT filings and payment deadline: individuals are to file by 31 March of the following year, while companies must file within six months after their year-end. Non-resident investors are to file immediately upon disposing of shares unless they intend to reinvest within the same year. Brokers or exchanges may be authorised to deduct CGT at source, and regulations may be issued to that effect;
• Transition arrangement: gains earned on shares up to 31 December 2025 will be taxed upon disposal under the law applicable as of that date; and
• Record keeping: investors are to maintain records of acquisition costs, sales proceeds, and related expenses for audit and verification purposes.

NIGERIA: NIPC announces transition from Pioneer Status Incentive to Economic Development Tax Incentive Scheme

In a public notice issued on 4 November 2025, the Nigerian Investment Promotion Commission ("NIPC") has announced that it is preparing to transition from the Pioneer Status Incentive ("PSI") to the Economic Development Tax Incentive ("EDTI") scheme as primary investment-tax incentive scheme. Consequently, the Commission stopped accepting PSI applications on 10 November 2025.

The EDTI scheme, introduced under the Nigeria Tax Act 2025, will take effect on 1 January 2026 It provides a 5% annual tax credit on eligible capital expenditures for up to 5 years, differing from the PSI, which offered a blanket tax holiday for the first 3 years.

NIGERIA: Large taxpayers urged to comply with E-Invoicing and Electronic Fiscal System

In a public notice issued on 6 November 2025, the FIRS has urged all large taxpayers with an annual turnover of at least NGN5-billion that have still to complete their integration with the National E-invoicing and Electronic Fiscal System (EFS) by the extended deadline of 1 November 2025 to do so immediately without further delay.

NIGERIA: Tax Ombudsman appointed to boost trust and accountability in Tax Administration

The federal government has announced the appointment, with effect from 1 January 2026, of Dr John Nwabueze as the Tax Ombudsman in accordance with the Joint Revenue Board of Nigeria (Establishment) Act 2025. The Act, introduced earlier this year as part of the Tax Reform Laws, establishes the office of the Tax Ombudsman to strengthen transparency and accountability in the tax system, enhance confidence in tax administration, and provide a structured mechanism for the fair and impartial resolution of disputes between taxpayers and revenue authorities.

NIGERIA: 1999 Constitution to be amended to curb multiple taxation

The National Assembly has completed the second reading of Bill HB 2545 which seeks to amend the 1999 Constitution of the Federal Republic of Nigeria. The Bill aims to:

• Align the revenue powers of the federation, states and local governments to promote efficiency;
• Define the scope of taxes and levies collectible by each tier of government;
• Prevent multiple taxation and unlawful outsourcing of revenue collection; and
• Introduce a ceiling on the number of income, consumption, or property taxes that may be imposed;
• Eliminate nuisance taxes and curb harassment by tax collectors;
• Enhance transparency, fiscal discipline, and accountability in tax collection; and
• Restore trust in the nation's fiscal system.

Significant proposed provisions of the Bill include:

• Clarifying that stamp duties imposed by the federal government apply only to documents and transactions involving corporate bodies, while stamp duties on transactions by individuals fall under state jurisdiction;
• Introducing a new expense item — VAT or consumption tax — into the exclusive legislative list to ensure national uniformity, predictability, and a clear constitutional basis for VAT administration by the federation;
• Prohibiting the outsourcing of tax collection to private entities;
• Introducing a ceiling on the maximum number of income, consumption, or property taxes that may be imposed in a year; and
• Streamlining local government taxation by removing redundant and overlapping taxing powers to prevent harassment of traders, artisans, and small businesses.

REPUBLIC OF CONGO: 2026 Finance Law adopted by the National Assembly and the Senate

The Finance Law 2026 was adopted by both the National Assembly and the Senate on 20 December 2025 and 22 December 2025 respectively, and entered into force from 1 January 2026, subject to its promulgation and publication in the Official Gazette. Significant proposed tax reforms include:

Direct taxation

• Harmonising the taxation of income from movable capital by applying a unified withholding tax rate of 15% on dividends, interest, bond income, distributed profits and capital gains on securities earned by both resident and non-resident individuals and entities while maintaining a 35% rate for undisclosed income. This unified rate replaces the previously differentiated rates of 20%, 17%, 15% and 10%. Withholding tax on movable capital is final if individuals and companies are not subject to corporate tax, or if it's earned by non-residents, whereas withholding tax for companies subject to corporate tax may or may not be final according to the State;
• Clarifying that income from movable capital is subject to withholding tax only when not included in the corporate income tax base;
• Introducing specific taxation of income derived from immovable property not subject to corporate income tax, by applying a 9% tax on rental income from built and unbuilt property and a 15% tax on capital gains arising from the disposal of immovable property;
• Introducing an investment tax credit to encourage investment in strategic sectors or regions, which is to be capped at 15% of eligible investment expenses such as acquisition of equipment, tools, and commercial or industrial buildings from unrelated companies. The investment tax credit may be carried forward for five years but it is subject to a sunset clause of expiration after five years unless renewed by Law;
• Shifting the taxation of individuals from a worldwide income assessment to a category-based system under which each type of income will be taxed separately according to its specific rules;
• Narrowing the scope of employment income tax exemptions by removing relief previously granted to certain categories of workers, while maintaining targeted exemptions for protected groups;
• Maintaining the employment income tax exemption applicable to salaries paid to persons living with disabilities;
• Introducing a final withholding tax of 15% on interest and similar income from claims, deposits and current accounts received by non-resident individuals;

Indirect taxation

• Introducing a carbon credit levy on promoters of speculative carbon credit generation projects developed within the country, subject to certain exclusions. The levy will:
  • be assessed on the volume of carbon credits effectively issued to the promoter, valued at the market transfer price on the date of issuance, with the higher market price at the date of declaration applying in the event of a subsequent increase;
  • apply at varying rates based on the following project classification: 20% for carbon credits generated from class 1 and 2 projects, and 15% for carbon credits generated from class 3 and 4 projects;
• Introducing a cybersecurity levy of 20% applicable to operators of electronic communications networks and digital service providers including online betting and gaming platforms, fund transfer certification platforms and electronic payment platforms. The levy is calculated on the revenue generated from the use of these platforms with payment due by the 5th day of each month;
• Introducing a full exemption from registration duties for certain short- and medium-term loan agreements granted by financial institutions and micro finance entities to employees and very small enterprises, subject to specific maturity and documentation conditions;

Administration

• Strengthening taxpayer registration rules by requiring all taxpayers to complete their registration in the national taxpayer register within strict statutory deadlines, while imposing penalties and operational restrictions in cases of non-registration;
• Expanding the powers of the tax administration to establish automated data-sharing bridges with public and private entities, thereby improving the reliability and completeness of the taxpayer register;
• Requiring public administrations and private entities to verify taxpayers' registration status and tax compliance before entering into commercial, financial or contractual relationships, including access to banking services, public procurement and cross-border transactions;
• Reinforcing sanctions against non-compliant taxpayers by introducing administrative measures such as suspension of operating licences, temporary or permanent closure of entities and blocking of bank accounts;
• Extending joint and several liability rules to public or private officials who knowingly facilitate transactions with unregistered taxpayers, thereby reinforcing accountability across the compliance chain;
• Strengthening audit and control mechanisms by improving access to third-party information and reinforcing the tax administration's ability to cross-check declarations through interconnected digital platforms;
• Modernising tax administration procedures through the progressive integration of electronic platforms for registration, declaration, payment and information exchange, with a view to enhancing efficiency and reducing compliance risks;
• Authorising the tax administration to monitor electronic transaction levies and carbon credit taxes;
• Extending the statute of limitations for the assessment of registration duties from 5 to 10 years, thereby expanding the tax administration's recovery period in respect of registrable acts;
• Reinforcing corporate reporting and disclosure obligations by expanding the information required to be filed with the tax administration, particularly in relation to payments made to suppliers, service providers and related parties;
• Integrating the tax and customs incentives applicable to approved developers and investors operating in special economic zones into the General Tax Code and the Customs Code, in line with the existing special economic zones legislation, and subjecting any abuse of such incentives to recovery under ordinary tax and customs rules; and
• Recognising electronic money services such as mobile money and airtel money, as authorized payment methods for taxes and duties.

RWANDA: participate in the signing ceremony for CARF MCAA and Addendum to CRS MCAA

On 2 December 2025, Rwanda participated in the signing ceremony for the Multilateral Competent Authority Agreement on Automatic Exchange of Information Pursuant to the Crypto-Asset Reporting Framework (CARF MCAA) and the Addendum to the Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information (2024) (Addendum to the CRS MCAA).

RWANDA: Negotiations for protocol to tax treaty with Mauritius underway

According to an update of 20 November 2025 published by the MRA, negotiations for an amending protocol to update the Mauritius - Rwanda Income Tax Treaty (2013) are underway.

SENEGAL: Law amending the General Tax Code approved by the National Assembly

The National Assembly has approved Law No. 2025-17 of 27 September 2025 amending the General Tax Code (Law No. 2012-31 of 31 December 2012) published in the Official Gazette on 2 October 2025. Significant amendments, which took effect on the day following the publication of Law No. 2025-17 in the Official Gazette on 2 October 2025, include:

• Introducing two new taxes on money transfer operations in the form of a 0.5% levy on payments received via money transfers collected by the mobile money operator, and a 0.5% tax on money transfers collected by the persons initiating the transfers, capped at F.CFA2 000;
• Introducing tax on games of chance at a rate of 20% withholding tax on winnings and on the income of gambling operators levied by the National Gambling Company, to be applied with effect from 1 November 2025 for the physical network and mid-November 2025 for the digital channel; and
• Extending the tax on passenger cars to imported vehicles; and
• Increasing the specific taxes on alcoholic beverages from 50% to 65% for imported alcoholic drinks and from 25% to 40% for local alcoholic drinks; and on tobacco products from 70% to 100%.

SIERRA LEONE: 2026 Budget Proposals released and 2026 Finance Bill enacted

The government has released the 2026 Budget proposals which aim to broaden the tax base, increase the corporate income tax rate and introduce stronger tax administration measures. The 2026 Finance Bill, which is proposed to take effect from 1 January 2026, was approved by Parliament on 27 November 2025. Significant measures include:

Direct taxation

• Increasing the corporate income tax rate from 25% to 30%;
• Expanding the scope of the minimum alternate tax to apply to all companies to address concerns about income tax evasion and avoidance;
• Increasing the withholding tax rate for non-resident capital income and other payments from 15% to 20%;
• Increasing the withholding tax rate on rental income from 10% to 15%;
• Removing the 5% investment allowance;

Indirect taxation

• Reinstating exemptions on goods and service tax (GST) for selected high-end goods and services, which include packaged/processed seafood, periodicals, magazines, and commercial or industrial water supply to manufacturing, commercial entities, and other industries;
• Introducing GST and import duty exemption on liquid petroleum gas (LPG) and its accessories, cooking stoves, solar panels and other home systems, consumed mainly by low-income households;

Administration

• Undertaking revenue administration, governance and integrity assessments;
• Developing compliance improvement plans for the extractive industry and large taxpayers;
• Strengthening petroleum import valuations and controls, and customs declaration and suspension regimes;
• Introducing an electronic single window for customs procedures;
• Conducting an audit of the automated system for customs data (ASYCUDA);
• Integrating the NRA existing data warehouse system with government digital platforms; and
• Enforcing taxation of digital services.

SIERRA LEONE: Tax treaty with United Arab Emirates enters into force

The Sierra Leone - United Arab Emirates Income and Capital Tax Treaty (2019) entered into force on 24 January 2023 and generally applies from 1 January 2019 for withholding and other taxes. This information only became available recently.

UGANDA: Post-exchange voluntary disclosure programme for foreign assets and income introduced

On 25 November 2025, the Uganda Revenue Authority ("URA") has launched, through a public notice, a post-exchange voluntary disclosure programme following the implementation of the Convention on Mutual Administrative Assistance in Tax Matters (MAAC) under the MAAC Implementation Act, Cap. 335.

The programme urges all Uganda tax residents with undeclared foreign assets or income to voluntarily disclose these before such information is used for audits and investigation. The initiative coincides with Uganda's commencement of receiving of automatic exchange of information (AEOI) data from 125 participating jurisdictions regarding offshore income and assets held by Ugandan tax residents.

The post-exchange voluntary disclosure programme operates in line with an earlier public notice issued on 20 December 2024 regarding voluntary disclosure of foreign assets. Under the updated framework, taxpayers may:

• Regularise their tax affairs and correct any errors or omissions in previously filed returns;
• Voluntarily declare offshore assets and income; and
• Benefit from a favourable treatment for compliance.

In order to receive the relief available under the voluntary disclosure framework, affected taxpayers are required to:

• Complete the voluntary disclosure foreign asset form available on the URA portal to declare foreign-held income or assets; and
• Amend their tax returns submitted over the last 3 years in accordance with section 25(3) of the Tax Procedures Code Act, Cap. 343, to reflect the newly disclosed offshore income or assets.

Tax relief would only apply where a taxpayer voluntarily provides accurate and complete information before it is detected by the URA or before the commencement of an audit or investigation.

ZAMBIA: Yaoundé Declaration signed

According to a press release of 4 December 2025 published by the Zambia Revenue Authority ("ZRA"), Zambia became the 36^th African country to endorse the Yaoundé Declaration on 28 November 2025, confirming its support for the regional initiative on tax transparency and the exchange of information for tax purposes, aimed at combating illicit financial flows through enhanced international tax cooperation.

ZAMBIA: Voluntary Disclosure Programme for Outstanding Tax Matters highlighted by Zambia Revenue Authority

On 12 December 2025 the ZRA has issued a public notice reminding taxpayers of the availability of the Voluntary Disclosure Programme ("VDP"), which allows taxpayers to regularise outstanding or unresolved tax matters.

Under the VDP, taxpayers may voluntarily disclose:

• Errors or omissions made in previous tax returns;
• Income, transactions or tax positions that were under-reported or inaccurately declared; and
• Income not declared by registered or non-registered businesses.

Where a disclosure is made in good faith, penalties and interest will not apply to the disclosed amounts. Taxpayers are strongly encouraged to take advantage of the programme to avoid penalties, and other future enforcement actions.

ZIMBABWE: Increase in gold royalty rates to be reversed

On 17 December 2025, the Ministry of Finance as announced a reversal of its earlier proposal to increase the gold royalty rates.

The Ministry of Finance had through the 2026 National Budget (presented on 27 November 2026), proposed increasing the gold royalty rate from 5% to 10% when the gold price exceeds USD2 500. However, the revised 2026 Budget Bill, approved by the National Assembly, retains the existing 5% royalty on gold sales where bullion prices range between USD1 200 and USD5 000 per ounce. Small-scale gold producers will continue to be subject to reduced royalties capped at 2%.

ZIMBABWE: Non-final deduction system calculation method in Tax and Revenue Management System deployed

On 25 November 2025, the Zimbabwe Revenue Authority (ZIMRA) has announced that the non-final deduction system (FDS) calculation methoed also known as the pay as you earn ("PAYE") system, was deployed on the tax and revenue management system (TaRMS) effective 1 November 2025.

The Non-FDS method, a non-cumulative approach for computing tax on employment income and applies to employees whose tax circumstances change during the year, applies to employees who:

• Terminate or change employment during the assessment year;
• Commence employment mid-year;
• Work part-time while fully employed elsewhere;
• Receive pensions; and
• Work for more than one employer within the same year.

Under the Non-FDS System, employers are required to:

• Deduct PAYE only according to the PAYE tables;
• Not apply any tax credits when calculating PAYE for non-FDS employees;
• Upload separate templates for FDS and Non-FDS employees under the employee management module in TaRMS;
• Submit one PAYE return per tax period with a consolidated position for both calculation methods;
• Amend any previously submitted returns to separate FDS and Non-FDS records; and
• Submit tax returns after the end of the year.

ZIMBABWE: 2026 National Budget presented

The Minister of Finance, Economic Development and Investment Promotion (MoFEDIP) has presented the 2026 National Budget to Parliament on 27 November 2025. Significant proposed tax amendments include:

• Increasing the VAT rate from 15% to 15.5%;
• Reviewing the royalty structure for all gold producers;
• Introducing withholding tax on VAT for imported digital services, which will be applied on payments made to offshore digital platforms; and
• Reducing the money transfer tax from 2% to 1.5% and designating the tax as a deductible expense.

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.