Africa: Tax

As SARS intensifies enforcement through data analytics and AI, taxpayers face increasing technical and procedural risks when disputing assessments. Understanding the objection process—from requesting reasons to meeting strict deadlines and providing proper documentation—can determine whether a tax dispute is resolved efficiently or escalates unnecessarily.

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

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

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

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

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

This issue of ENS' tax in brief provides a comprehensive snapshot of the latest tax developments in South Africa, including VAT notices, SARS publications, advance tax rulings, and customs and excise updates. The bulletin covers critical updates on VAT modernisation consultation, binding private rulings on employee incentive trusts and loan claim distributions, and tariff amendments affecting traveller allowances and agricultural tire imports.

Nigeria's Revenue Service has issued comprehensive guidelines establishing the country's first administrative framework for taxing virtual assets and cryptocurrency transactions. The new rules classify digital assets into six categories and outline detailed compliance obligations for individuals, companies, and Virtual Asset Service Providers operating in Nigeria's digital economy.

Nigeria has introduced comprehensive tax guidelines for virtual assets, requiring VASPs to withhold taxes, collect stamp duties, and maintain detailed records. The new framework classifies crypto assets into six categories and imposes income tax, VAT, and stamp duty on various transactions, fundamentally changing compliance obligations for cryptocurrency platforms operating in Nigeria.

Nigeria has introduced a standardised framework for the taxation of virtual assets through the NRS Virtual Asset Tax Guidelines. This comprehensive breakdown examines who the guidelines apply to...

Kenya's legal and regulatory landscape is undergoing significant transformation across multiple sectors, from the introduction of Africa's first dedicated technopolis legislation to the establishment of comprehensive cryptocurrency licensing requirements. The country is implementing major reforms in banking capitalisation, ending Kenya Power's retail electricity monopoly, and expanding its tax framework to capture digital financial services and indirect share transfers.

The Tax Court in Cape Town has ruled on a dividend stripping arrangement used in the sale of a self-storage business, applying South Africa's general anti-avoidance rules to a structure where shareholders attempted to convert taxable capital gains into exempt intercompany dividends. Following the Constitutional Court's recent decision in Absa Bank Ltd v SARS, the Court examined whether a pre-acquisition dividend funded by the purchaser's subscription served any purpose beyond tax avoidance, and whether the