Africa Tax In Brief - 14 July 2026

ANGOLA: Additional tax incentives for oil blocks approved

On 22 June 2026, the Council of Ministers approved proposals authorising the President to enact Presidential Legislative Decrees granting targeted tax incentives for the concession areas of Blocks 33/24 for Chevron, 17/25 and 32/21 for TotalEnergies, and 19 for British Petroleum (BP). The Presidential Legislative Decrees, aimed at improving the competitiveness of marginal fields and deepwater blocks, need to be formally enacted following the authorisation process.

The new incentives include:

• Enhanced tax benefits for operators in both new and existing oil blocks, such as reductions in tax rates and improved terms under Production Sharing Agreements;
• Extensions of tax holidays, accelerated depreciation regimes; and
• Targeted relief on import duties and other indirect taxes related to exploration and development activities.

ANGOLA: Personal Income Tax Code passed by National Assembly Specialised Working Committee

Angola's National Assembly Specialised Working Committee approved the draft Law introducing the unified Personal Income Tax Code (Código do Imposto sobre os Rendimentos de Pessoas Singulares, IRPS) on 16 June 2026.

The Tax Code, which will enter into force on 1 January 2027 following its promulgation by the President, will replace the current fragmented system with a single modern framework covering all personal income categories, including employment, business/professional, capital, real estate, and capital gains.

ANGOLA: 5% special tourism contribution introduced

On 30 April 2026, Angola issued Presidential Legislative Decree No. 4/26, introducing a special tourism contribution (Contribuição Especial para o Turismo, (“CET”)) at a rate of 5%. The Decree, which will enter into force 90 days after publication, applies only to international tourists aged 12 years and above who stay in tourist resorts or local accommodation establishments.

The contribution is charged at 5% of the daily room rate per overnight stay, up to a maximum of seven nights and is due at the time of check-in or check-out of the tourist resort or local accommodation establishment. It must be clearly shown on the invoice.

Accommodation providers are responsible for:

• Collecting the CET and remitting the amounts to the competent authority by the last business day of the month following the month in which it was collected; and
• Maintaining auditable records of all collections, including invoices, receipts, monthly collection maps, credit notes and any additional information as may be required by the tax authority.

BENIN: 8% increase in State Budget approved in draft 2026 Amending Finance Law

Following the restructuring of the government administration, on 3 June 2026 Benin's Council of Ministers approved a draft 2026 Amending Finance Law increasing the state budget by 8% compared to the initial finance law. The draft 2026 Amending Finance Law is currently under consideration by the National Assembly.

BOTSWANA: 2026 Tax Law amendments gazetted

On 30 June 2026, The Income Tax Act, 2026 (Act 13 of 2026), Tax Administration Act, 2026 (Act 14 of 2026), Value Added Tax (“VAT”) Act, 2026 (Act 15 of 2026) and Customs (Amendment) Act, 2026 (Act 16 of 2026) were gazetted and, together with a suite of supporting statutory instruments, came into effect on 1 July 2026 (subject to a few exceptions under the VAT Act). Significant amendments include:

• Increasing the corporate income tax rate to 24.5%, with mining companies being taxed at the variable mining rate (the higher of a statutory formula or 24.5%). Diamond mining companies in which the Government holds an equity interest will pay the 24.5% flat rate;
• Increasing the top marginal income tax rate for resident individuals earning taxable income exceeding BWP400 000 to 27.5%;
• Revoking the 1990 Employment Income Regulations and replacing them with a comprehensive new benefit valuation framework for employee benefits, including housing, motor vehicles, school fees, and utilities;
• Introducing the Income Tax (Transfer Pricing) Regulations, 2026 (Statutory Instrument No. 189);
• Providing that where a taxpayer makes a partial payment against a combined tax, interest and penalty liability, the payment is applied first against the tax, then against the late payment interest, and finally against the penalty (the opposite of the previous allocation order);
• Providing that the electronic billing system will commence nine months from the date of commencement of the Tax Administration Act (approximately 1 April 2027); and
• Requiring companies carrying on a relevant business to file a substance report with the Commissioner General within three months of the end of the tax year, setting out the company’s core income-producing activities, management body composition, employees, expenditure and physical presence in Botswana.

BOTSWANA: Regulations for government entities and large unregistered persons concerning VAT reverse charge supplies issued

On 29 May 2026, Botswana issued the VAT (Government Entities and Large Unregistered Persons) Regulations 2026 (Statutory Instrument No. 73 of 2026), prescribing registration and compliance requirements for government entities and large unregistered persons concerning reverse-charged supplies under the VAT (Amendment) Act No. 16 of 2025.

The Regulations require government entities and large unregistered persons to:

• Apply for VAT registration and account for reverse-charge supplies. Applications must be made in a prescribed form and should include:
  • the registered name of the government entity or large unregistered person;
  • the address, telephone number and electronic contact details of the applicant;
  • details of the business activities or functions carried out by the applicant; and
  • the name and contact details of the person responsible for VAT compliance;
  • a letter from an accounting officer or a board resolution approving the registration;
• Make all VAT registration applications within two months from the commencement of the VAT (Amendment) Act, 2025 and
• Begin accounting for reverse-charged supplies upon the expiry of the two-month transitional period (August 2026).

BOTSWANA: Implementation timelines for VAT on remote services outlined

On 29 May 2026, the Botswana Unified Revenue Service (“BURS”) published a public notice outlining the implementation timelines, registration windows and filing deadlines for the VAT (Amendment) Act No. 16 of 2025, which became effective on 1 June 2026, introducing a tax framework for remote services supplied by non-resident providers.

The VAT Amendment Act had been enacted in October 2025, introducing new provisions relating to remote services, electronic marketplaces, reverse charge obligations and electronic tax administration measures. The notice provides that:

• Registration for non-resident suppliers of remote services commenced on 1 June 2026. Affected non-resident suppliers must officially begin charging VAT on their taxable supplies on 1 October 2026;
• Government entities and large unregistered persons with annual turnover exceeding BWP1-million must commence tax registration from 1 August 2026. Existing registered persons must begin accounting for reverse-charged supplies of remote services from 1 August 2026; and
• Supplies imported before transitioning into the new reporting framework must continue to be reported via the declaration of value added tax due on imported service (Form VAT.017.1);

On the same date, the BURS issued the VAT (Remote Services) Regulations 2026 (Statutory Instrument No. 74 of 2026), establishing the administrative framework for the taxation of remote services supplied by non-resident service providers and electronic marketplace operators. The Regulations include:

• The scope of remote services supplied into Botswana;
• The requirements for the application and registration for VAT. Upon registration, the Commissioner General will issue the supplier with a VAT registration number;
• Required documents to accompany the registration;
• The requirement that:
  • VAT returns must be submitted and VAT paid on or before the 25^th day of the month following the end of the relevant tax period;
  • Registered suppliers must issue electronic tax invoices showing the recipient's name and VAT registration number and maintain invoices and records for at least five years;
• Remote service suppliers may appoint representatives to fulfil their VAT obligations, including filing returns and remitting tax. The appointment must be notified to the Commissioner General;
• Remote service suppliers making supplies to VAT-registered customers are required to obtain the customer's VAT registration number;
• Registered suppliers must issue electronic tax invoices showing the recipient's name and VAT registration number; and
• As a transitional measure, suppliers that are liable to register under the remote services provisions are required to register immediately upon commencement of the VAT Act (June 2026). Such suppliers are required to begin charging VAT four months after registration (October 2026).

BURKINA FASO: Local country-by-country reporting obligation suspended

Circular No.2026-02020/MEF/SG/DGI, issued on 29 June 2026, announced the suspension of the local filing obligation for country-by-country (“CbC”) reports for companies operating in the country during the 2023, 2024 and 2025 fiscal years due to technical constraints.

The suspension applies to companies required to file a CbC report under article 98-2(2) and (3) of the General Tax Code (Code général des impôts, CGI) where the company is:

• Held directly or indirectly by an entity established in a jurisdiction that does not require CbC reporting but that would be required to file if established in Burkina Faso;
• Held directly or indirectly by an entity established in a jurisdiction not included on the list provided for under article 98-2(8) of the CGI but with which Burkina Faso has concluded a tax information exchange agreement; or
• Held directly or indirectly by an entity established in a jurisdiction on the list provided for under article 98-2(8) of the CGI where a systemic failure of the jurisdiction of the ultimate parent entity has been notified by the tax administration.

The CbC reporting obligation was introduced by the Finance Law for fiscal year 2023 and applies to fiscal years opened from 1 January 2023.

CABO VERDE: Automatic Exchange of Financial Account Information to be implemented by 2027

According to a press release of 26 May 2026, published by the OECD, Cabo Verde has committed to implement the international Standard for Automatic Exchange of Financial Account Information in Tax Matters (AEOI) by September 2027. This commitment makes Cabo Verde the 130^th Global Forum member to commit to start AEOI by a specific date.

CAMEROON: List of 112 states for Automatic Exchange of country-by-country reports published

Through Arrêté No. 00000527/MINFI, which was signed on 10 June 2026 and entered into force on the same date, Cameroon's Ministry of Finance has published a list of 112 jurisdictions with which Cameroon has an agreement in force authorising the automatic exchange of CbC reports for fiscal years commencing on or after 1 January 2026.

The list implements the multilateral competent authority agreement on the exchange of CbC reports signed by Cameroon on 24 January 2024 and includes, among others, France, Germany, United Kingdom, China, Japan, Canada, Brazil and India, most other EU Member States, as well as African jurisdictions, including Benin, Gabon, Kenya, Liberia, Mauritania, Morocco, Nigeria, Senegal and South Africa.

CôTE D’IVOIRE: VAT treatment of disbursements under e-invoicing system clarified

Through Note de Service N° 02502/MEFB/DGI/DLCD-SDL/gr/05-2026, issued on and effective from 18 May 2026, the General Tax Directorate (Direction générale des Impôts, DGI) has clarified the conditions under which disbursements recorded in the normalised electronic invoicing system (facturation normalisée électronique, (“FNE”)), remain outside of the VAT base.

Disbursements (costs incurred by a service provider in the name and on behalf of a client) remain outside the VAT base where:

• They are reimbursed and do not constitute consideration for a service, even at cost price;
• The provider has received a mandate from the client to pay the relevant amounts; and
• The provider accounts in detail for the nature and amount of each expense incurred.

Where these conditions are met, the disbursements must be recorded on a separate note transmitted through the FNE platform alongside the electronic invoice. Pending the implementation of a dedicated "disbursements" section in the FNE system, amounts must be entered under the "other mentions" section. Otherwise, the amounts will be treated as income or turnover subject to VAT.

DEMOCRATIC REPUBLIC OF THE CONGO: Draft decree on plastic waste recycling tax incentives adopted

On 29 May 2026, the Council of Ministers has adopted a draft decree establishing tax incentives for plastic waste collection, recycling and processing activities. The measure is intended to promote the circular economy, support national industrialisation and reduce the environmental impact of plastic waste.

The decree defines the framework for the tax incentive regime, establishes an inter-ministerial monitoring commission and limits the duration of benefits to 24 months, renewable following evaluation.

DJIBOUTI: Remittance tax and digital supervision platform for outbound international transfers introduced

Through Arrêté No.2026-087/PR/MB, signed on 12 April 2026 and published in the Official Gazette of the Republic of Djibouti on 6 May 2026, Djibouti has issued implementing rules for the collection, declaration and remittance of the tax on outbound international transfers, effective from 1 January 2026.

The tax, introduced by the 2025 Supplementary Finance Law, applies at a rate of 0.2% on outbound transfers. Transfers below FDJ53 316.30 are exempt and the tax is capped at FDJ17 721 per transaction.

Banks, mobile telecommunications companies and licensed money transfer operators are required to collect the tax at source, file a monthly declaration with the tax administration, and remit the amounts collected to the Treasury by the 10^th of the month following collection by bank transfer to the Treasury account.

Arrêté No. 2026-088/PR/MB, signed on 13 April 2026 and published in the Official Gazette of the Republic of Djibouti on 6 May 2026 established a national digital platform for the supervision of outbound international transfer transactions.

The platform is intended to centralise, process and analyse transaction data transmitted by operators for tax supervision and public revenue protection purposes. In particular, it:

• Centralises transaction flows transmitted by operators;
• Automates verification of the taxable base and the calculation of tax due; and
• Generates dashboards, alerts and compliance reports.

Banks, mobile telecommunications companies and licensed money transfer operators are required to transmit data relating to outbound international transfers through the platform in real-time or near real-time and ensure that their systems comply with technical standards set by the tax administration.

ESWATINI: Practice note on retirement fund contributions issued

On 12 June 2026, the Eswatini Revenue Service (“ERS”) issued Practice Note No. COM–IT/03/26 on retirement fund contributions made by employers and employees, which comes into effect on 1 July 2026. The Practice Note guides employers and employees on the acceptable minimum and maximum contribution rates for retirement funds and the conditions under which contributions may obtain approval for income tax purposes.

The Practice Note provides inter alia that:

• As soon as practicable after the Practice Note comes into force, every employee who is a member of an employer-created fund for the benefit of the employee and the employee's dependants must contribute a minimum of 5% and a maximum of 15% of pensionable salary to the fund;
• As soon as practicable after the Practice Note comes into force, every employer must contribute to the relevant fund at a rate equal to the employee's contribution rate, or twice that rate, subject to a maximum of 20%;
• Contributions required under the Practice Note are a condition of employment;
• The Commissioner General may require monthly statements showing contributions made towards employees' retirement, identifying newly admitted employees and separately reflecting employer and employee contributions; and
• The Commissioner General may inspect employee contracts, payslips, board meeting minutes and other relevant documents to determine whether a fund is eligible for approval under the Practice Note.

GAMBIA: E-invoicing System Regulation approved

On 22 June 2026, the Gambia Revenue Authority (“GRA”) issued a public notice announcing the Cabinet's approval of the Electronic Invoicing (E-Invoicing) System Regulation, which governs the implementation of an e-invoicing system for VAT and other taxes launched in July 2025.

The GRA confirms will begin with a pilot phase involving a selected group of taxpayers from various economic sectors and will provide guidance and support to participating taxpayers throughout the pilot period, allowing it to test, refine and optimise the system before nationwide deployment.

GUINEA: Online registration procedure through eTax/SAFIG2 launched

Through Communiqué No. 005 under reference No. 1387/MEFB/DGI/2026, signed on 19 May 2026, the General Directorate of Taxes (DGI) launched a new procedure for the management of registration deeds through the eTax/SAFIG2 platform.

The reform, which is effective from 1 June 2026, applies to registration formalities relating inter alia to agreements, lease contracts, public procurement contracts, notarized deeds and other registrable acts, which will henceforth be carried out exclusively online through the eTax/SAFIG2 platform.

The new system will allow for the remote submission and monitoring of files on a 24/7 basis; secure payment through banks or Mobile Money services; shorter processing times; and the allocation of a unique verification QR code intended to ensure the authenticity of registered acts.

KENYA: Finance Bill 2026 assented to by the President

On 24 June 2025 the President assented to the Finance Bill 2026, thereby enacting it into law as the Finance Act 2026 and introducing various tax amendments with effect from 1 July 2026. Significant amendments include:

• Introducing a separate deduction category for mortgage interest relief of up to KES360 000, applicable to loans advanced by the Central Bank of Kenya to employees for the construction, purchase or improvement of an occupied house;
• Expanding the VAT exemption list to include the transportation of sugarcane from farms to milling factories, as well as the supply of specified electric motorcycles, electric bicycles and electric buses; and
• Establishing a six-month amnesty period from 1 July to 31 December 2026 during which penalties and interest are waived on outstanding principal tax liabilities incurred up to 31 December 2025, provided that the principal amount is fully settled by 31 December 2026.

KENYA: Draft regulations on residential rental income tax and the set-off tax rebate for graduate apprenticeships released

In a Public Notice issued on 29 April 2026, the Revenue Authority (“KRA”) released the:

• Draft Income Tax (Residential Rental Income Tax) Regulations 2026; and
• Draft Income Tax (Set-Off Tax Rebate for Graduate Apprenticeships) Regulations 2026.

The draft Income Tax (Residential Rental Income Tax) Regulations, 2026 are aimed at providing a simplified final withholding tax regime for resident persons earning rental income from residential property, specifically gross annual rents of between KES288 000 and KES15-million.

The draft Income Tax (Set-Off Tax Rebate for Graduate Apprenticeships) Regulations, 2026 are aimed at operationalising the tax rebate provided for under section 39B of the Income Tax Act, offering an incentive to employers that engage graduate apprentices for work training. The Regulations inter alia:

• Provide that eligible employers are entitled to a tax rebate equal to 50% of the salaries and wages paid to such graduate apprentices, treated as an allowable expense for income tax purposes;
• Establish a formal process requiring employers to obtain written permission from the Director-General of the Industrial Training Authority, enter into a registered contract of apprenticeship, and obtain a certificate of apprenticeship upon completion;
• Require the Director-General to submit quarterly reports to the KRA Commissioner containing particulars of employers (including personal identification numbers (PINs)) and apprentices, the number engaged, and the duration; and
• Mandate employers to maintain certified copies of apprenticeship contracts and certificates for a period of five years from the end of the year of income.

LIBERIA: Multi-source tax strategy for health insurance rollout proposed

On 23 June 2026, the Ministry of Health presented the National Health Insurance Bill to the President. The Bill proposes several statutory contributions and levy streams to finance the national health insurance scheme, including:

• 5% to 1.0% in salary deductions, to be paid through the National Social Security and Welfare Corporation (NASSCORP) and shared between employers and employees, with the exact rates to be prescribed by regulation;
• 1% to 3% of VAT, with the exact percentage to be determined;
• A 1% surcharge on all mobile money transactions conducted in Liberia;
• Mandatory contributions from Class A and Class B mining concession companies, at amounts to be prescribed by regulation;
• Periodic lump-sum contributions from informal sector participants, collected through unions, associations, and other recognised groups and remitted by the Liberia Revenue Authority;
• 10% of total excise tax collections;
• 5% of revenues derived from environmental pollution-related activities and other relevant taxes imposed on manufacturers and distributors; and
• Levies on companies providing health and health-related insurance services.

The Bill has not yet been enacted and requires legislative approval.

LIBERIA & SIERRA LEONE: MoU on simultaneous tax examinations signed

On 19 June 2026, the Liberia Revenue Authority announced that Liberia and Sierra Leone have signed a memorandum of understanding (“MOU”) on simultaneous tax examinations. The MoU aims to facilitate cooperation in addressing cross-border taxation risks and illicit financial flows; reinforce international best practices in tax administration; improve tax compliance among multinational businesses; and support regional economic integration in the fight against tax evasion.

MALAWI: Tax Amendment Acts 2026 enacted

On 9 April 2026, the President assented to the 2026 Tax Amendment Act, which were published in the Gazette on 14 April 2026 and entered into force on 15 April 2026. Significant amendments include:

Direct taxes

• Reducing the taxable income threshold for companies subject to the 10% additional corporate income tax, from MWK10-billion to MWK5-billion;
• Introducing a final 15% withholding tax on gross rental income earned by individuals from residential property;
• Imposing a separate 10% withholding tax on payouts from casino gaming, which were previously taxed under the general category of betting and gambling winnings at a rate of 15%;
• Repealing the current capital gains tax on the disposal of listed shares and substituting it with a final 2% withholding tax on the gross proceeds from the sale of such shares. The withholding tax does not apply to:
  • listed shares disposed of by a person exempt from income tax; or
  • a person disposing of shares to use the proceeds from the disposal immediately to invest in other listed shares;
• Clarifying that the levy on mobile money and bank transfers is a non-allowable expense;
• Providing for a deduction for farm water works, including dams and dikes used for irrigation;

Indirect taxes

• Increase the annual threshold for mandatory VAT registration from MWK25-million to MWK50-million;
• Introducing VAT on the supply of digital services, applicable to non-resident digital service suppliers, intermediaries or electronic marketplace operators, irrespective of whether the value of their taxable supplies meets the VAT registration threshold of MWK50-million per annum. An input deduction is not allowed for transactions in respect of digital services by non-resident digital services suppliers, intermediaries or electronic marketplace operators;
• Repealing the input tax deduction on purchases or imports in respect of exempt supplies by the taxable person;
• Clarifying the definition of "electronic marketplace operator", which refers to a person who operates a digital platform that facilitates a supply of digital services to recipients in Malawi;
• Clarifying the definition of "intermediary", which refers to a person who facilitates the supply of digital services supplied by a digital services provider to recipients in Malawi and who is responsible for issuing the invoices and collecting payment for the supply; and
• Expanding the list of zero-rated items to include buses with a seating capacity of 45 or more and building materials to be used in the tourism industry;

 Administration

• Requiring taxpayers who have received an audit notice in respect of transfer pricing and other related‑party arrangements to retain all relevant records and documentation for audit purposes until receipt of an audit completion notice from the Commissioner‑General;
• Extending the period within which an additional assessment arising from the transfer pricing audits can be issued by the Commissioner, from six to nine years;
• Introducing the electronic service of documents, under which the Commissioner General or a tax officer may electronically serve a document on a person by sending it to that person's last known electronic address, including the registered email address, the last known email address, or the last known telefax number;
• Increasing the penalty for non-compliance with Commissioner General's notice to produce transfer pricing local file documentation from MWK1-million to MWK40-million;
• Changing the mineral royalty payment period from quarterly to monthly; and
• Reducing the period within which a taxpayer may claim excess input VAT from 12 years to six years.

MAURITIUS: 2026/2027 Budget delivered

On 19 June 2026, the Mauritius Prime Minister and Minister of Defence, Finance, and External Affairs presented the 2026/2027 Budget Speech in the National Assembly. Significant proposed amendments include:

• Providing that the 3% reduced corporate income tax rate on profits derived from the export of goods will not apply to the export of live animals;
• Extending the 10-year tax holiday granted to captive insurance companies for a period of five years for captives issued with a licence prior to 19 June 2026;
• Extending the investment tax credit of 15% over three years granted to manufacturing companies in respect of expenditure incurred on the acquisition of new plant and machinery, artificial intelligence solutions, and patents for a period of three years on qualifying investment incurred up to 30 June 2029;
• Reducing the annual allowance rate for capital expenditure incurred on hotels from 30% to 15%;
• A new top personal income tax rate of 35% on chargeable income exceeding MUR12-million, replacing the fair share contribution for individuals;
• An four-year income tax exemption for qualifying expatriate employees of companies engaged in the manufacturing of solar photovoltaic systems;
• Introducing an insurance premium tax with effect from 1 January 2027, at a rate of 5% on short-term general insurance, which will apply to all new and renewed policies;
• Amendments to the scope of Tax Deduction of Source; the Qualified Domestic Top-Up Tax regime; and the Corporate Climate Responsibility Levy;
• Providing that foreign suppliers of electronic services will not be required to:
  • register for VAT purposes if they make taxable supplies exclusively to a VAT-registered person, in which case the VAT reverse charge mechanism will apply;
  • appoint a tax representative for the submission of returns and the remittance of VAT;
  • compulsory register for VAT if their annual taxable supplies is less than MUR3-million;
• Introducing a framework to facilitate the early resolution of tax matters, under which the MRA and a taxpayer may enter into a binding written compliance agreement regarding the taxpayers liability under any Revenue Law prior to the issuance of an assessment or claim

MAURITIUS: Privy Council rules in favour of claiming 80% exemption on interest income

On 30 July 2026, the Privy Council ruled in favour of Alteo Energy Limited (“Alteo”), confirming that it was entitled to claim the 80% exemption on interest earned during the tax year ending 30 June 2019.

Alteo’s main business is the production and sale of electricity. During the tax year ended 30 June 2019, it derived income from the sale of electricity as well as interest income on excess cash deposited with a sister company. Alteo claimed the 80% exemption of interest under the Second Schedule to the Income Tax Act, which allows companies to be partially exempt from income tax on interest received, provided that the following substance requirements are met:

• The company carries out its core income generating activities in Mauritius;
• The company directly or indirectly employs an adequate number of suitably qualified persons to conduct its core income generating activities; and
• The company incurs a minimum expenditure proportionate to its activities.

The MRA denied Alteo’s claim for the 80% interest exemption on the basis that the substance condition was not met, as the interest income represented only 0.25% of the total income of company and its lending activities were incidental to its main electricity business.

The Assessment Review Committee ruled in favour of the MRA and Alteo subsequently appealed to the Supreme Court, which ruled in its favour on the basis that:

• Any company (other than excluded financial institutions) may claim the exemption and there is no restriction such as the nature of business activities;
• The only requirement to be met is that the company satisfies the conditions relating to the substance of its activities as prescribed; and
• “Core income generating activities” should be given its natural meaning, i.e. any business activities which generate the main income of the company as well as the extended statutory meaning given to it for purposes of claiming the partial exemption.

The MRA appealed to the Privy Council, which dismissed the appeal inter alia on the basis that:

• In the present context, “income” meant income of the type capable of benefitting from the relevant exemption, i.e. interest income; and
• The word “core” qualifies the relevant “income generating activities”, not the company’s overall business. The condition therefore asks whether the core activities required to generate the relevant income were carried out in Mauritius, not whether the money-lending was central to Alteo’s business.

MAURITIUS: Protocol to tax treaties with Bangladesh and Jersey enter into force

The amending protocol, signed on 5 February 2024 and 9 April 2024 by Mauritius and Bangladesh, respectively, to the Bangladesh - Mauritius Income Tax Treaty (2009) entered into force on 10 October 2024. The protocol generally applies from 1 July 2025 for withholding and other taxes.

On 24 March 2026, the amending protocol, signed on 8 July 2024 and 9 August 2024 by Jersey and Mauritius, respectively, to the Jersey - Mauritius Income Tax Treaty (2017) entered into force. The treaty generally applies from 1 July 2026 for Mauritius and from 1 January 2027 for Jersey for withholding and other taxes.

The protocols bring the treaties in line with the latest international standards, following the OECD/G20 Base Erosion and Profit Shifting (BEPS) recommendations.

MAURITIUS: DMTT filing and payment deadline extended to 30 June 2026

In a Communique issued on 26 April 2026, the MRA has announced an extension of the deadline for the submission of domestic minimum top‑up tax (“DMTT”) returns and the payment of the corresponding tax. Where the statutory deadline for submission and payment falls between 1 April 2026 and 29 June 2026, such deadline has been extended to 30 June 2026.

The DMTT applies from the year of assessment commencing on 1 July 2025 and is relevant to resident entities forming part of an in-scope multinational enterprise group, with a fiscal year ending on or after 1 January 2025. Under the Income Tax Act, the designated entity within the MNE group is required to file the DMTT return and settle any tax payable within 15 months from the end of the fiscal year.

NIGER: VAT deferral rules for public sector suppliers clarified

Through Circular N°00041/ME/F/SG/DGI/DL/CFI/DIV.L/SEL, issued on 6 June 2026, Niger clarified the conditions and procedures for deferring the VAT liability on supplies of goods and services made to the state, local authorities and their non-commercial entities.

Eligible suppliers may request the deferral after the relevant contract has been approved by the competent authorities. The request must be addressed to the Director General of Taxes and accompanied by a copy of the contract, procurement document or equivalent document, as well as the relevant invoices or payment statements.

Under the deferral, VAT becomes due only when the receivable is actually paid by the Treasury or the competent public body, thereby aligning VAT chargeability with the supplier's actual receipt of payment and the corresponding VAT withheld at source.

For VAT return purposes, suppliers report turnover and VAT for the period in which payment is actually received, deducting the VAT withheld at source. For instalment payments, these rules apply proportionally to each amount actually received.

The VAT deferral has no effect on the determination of turnover or taxable income, which remain subject to accrual accounting rules.

NIGER: Tax penalty relief thresholds made legally binding

Niger issued a ministerial order, Arrêté n°000199/ME/F/SG/DGI/DL/CFI signed on 15 May 2026, making legally binding the authority thresholds for granting penalty waivers and reductions following tax audits, as per the guidance issued on 12 March 2026. The thresholds are as follows:

• Regional tax directors may grant waivers or reductions up to F.CFA25-million;
• The national technical director may act up to F.CFA50-million;
• The director general of taxes may act up to F.CFA500-million; and
• Amounts above that threshold require ministerial approval.

NIGER: Electronic tax communications given legal effect

Niger issued a ministerial order, Arrêté n°000167/ME/F/SG/DGI/DL/CFI signed on 4 May 2026, allowing the tax administration to conduct official communications with taxpayers electronically, with such communications having the same legal effect as paper documents where the applicable digital requirements are met.

The order provides that:

• Electronic communications must use the secured portals, information systems and electronic addresses designated by the tax administration;
• Access and transmission require secure digital identification and recipients are responsible for the confidentiality of their credentials;
• Electronic documents must be time-stamped, identify the sending service and recipient, carry a qualified electronic signature or electronic seal where applicable, and be archived for a minimum of 10 years;
• Each transmission gives rise to an acknowledgement of receipt, stored in the user's secure space, with the same evidentiary value as a postal acknowledgement or physical discharge;
• Electronic communications are deemed delivered at the date and time of dispatch from the tax administration's platform. Where transmission fails due to a fault attributable to the recipient, notification must be made by another authorised method;
• Technical records, timestamps and archived messages are enforceable against both taxpayers and the tax administration in disputes over the date, content or consequences of a communication; and
• Communications requiring physical presentation of items or seals, or an in-person hearing, remain outside the scope.

NIGER: Technical standards for digital accounting file submission set

Niger issued Arrêté n°000166/ME/F/SG/DGI/DL signed on 4 May 2026, introducing technical standards for taxpayers using computerised accounting to submit a standardised digital accounting file (fichier des écritures comptables, (“FEC”)) when requested by the tax administration during a tax audit.

The requirement applies to all taxpayers using computerised accounting systems, regardless of size or tax regime. The FEC must cover all entries for the fiscal year, including opening balances, inventory and closing entries, in chronological order.

The FEC must be submitted within five working days of the tax administration's request, either by upload to a secured portal or on a sealed external device against receipt. Files must be in delimited text format (CSV) and include the specified detail for each entry, in the prescribed order:

The following documents must accompany the FEC:

• The chart of accounts;
• Journals, general ledger, trial balance, client and supplier lists with tax identification numbers; and
• Transaction amounts, depreciation schedule and provisions schedule.

Taxpayers must make available, on request, documentation on the system architecture, integration procedures, internal controls and access rights. They must also retain the FEC export notice, data dictionary, matching rules, fiscal-year parameters and access profiles.

If the file is formally rejected for non-compliance relating to format, fields or balance, the taxpayer has 48 hours to submit corrections. Serious failures including incomplete files, data alteration or refusal to submit, are recorded in a formal report and give rise to penalties. Files and audit logs must be retained for a minimum of 10 years.

A simplified FEC limited to cash and purchase/sales journals may be accepted for lump-sum taxpayers when requested by the tax administration.

NIGER: Scope of tax on certain corporate general expenses clarified

Nigeria issue a ministerial order, Arrêté n°000159/ME/F/SG/DGI/DL signed on 4 May 2026, clarifying the persons, expenses, vehicles, goods and services subject to the Tax on Certain Corporate General Expenses (Taxe sur Certains Frais Généraux des Entreprises, (“TCFGE”)). This follows the reduction of the tax rate from 28% to 20% under the new General Tax Code.

The order applies to all TCFGE taxpayers operating in Niger and covers expenses incurred during the fiscal year preceding the year in which the tax becomes payable.

Covered persons include legal and de facto managers, directors, partners, sole proprietors, employees and their relatives, as well as third parties benefiting from company-provided assets or services. The scope also extends to individuals connected to related entities or service providers through intragroup arrangements or similar influence relationships.

Taxable items include motor vehicles and pleasure aircraft made available by the company, non-operational immovable property, furniture, utilities, domestic staff and taxes, duties and penalties borne by the company on behalf of covered persons. The order also sets out specific valuation rules for each category.

Taxpayers must maintain a register of beneficiaries indicating their names, the goods and services provided, periods of use and the allocation between professional and private use. In the absence of such records, the allocation is made as in accordance with the rules applicable to corporate income tax and business profits tax purposes.

NIGER: Rules for non-cooperative jurisdictions issued

Niger issued a ministerial order, Arrêté n°000170/ME/F/SG/DGI/DL/CFI signed on 4 May 2026, defining non-cooperative states and territories and establishing reporting obligations for taxpayers making payments to persons resident or domiciled in such jurisdictions, with effect from the same day.

Under the order, a jurisdiction may be classified as non-cooperative where it:

• Refuses to exchange information with Niger or lacks an operational exchange relationship;
• Receives unfavourable assessments by international evaluation bodies on tax transparency and exchange of information; or
• Displays substantial and repeated failures in the effectiveness of exchanges.

The list of non-cooperative states and territories is determined by reference to classifications established by international, regional and sub-regional bodies.

Taxpayers making payments to any individual or legal entity resident or domiciled in a listed jurisdiction must file an annual declaration with the tax administration, reporting the amounts paid, by beneficiary and by nature of payment, using a form prescribed by the tax administration. Supporting documentation must be retained for a minimum of 10 years.

In the event of a tax audit, the taxpayer must produce contracts, invoices, payment records, ultimate beneficial ownership information and any relevant correspondence enabling the tax administration to verify the non-cooperative status of the jurisdiction at the date the expense became due.

NIGER: Transfer pricing documentation rules for multinationals issued

Niger issued a ministerial order, Arrêté n°000164/ME/F/SG/DGI/DL/CFI of 4 May 2026, setting out the minimum transfer pricing documentation requirements for multinational enterprise groups operating in Niger.

The order, which implements article 793 of the General Tax Code (Code Général des Impôts, CGI), requires covered entities to maintain two complementary files: a master file relating to the group as a whole and a local file relating to the Niger entity and its related-party transactions.

Documentation must be prepared in the working language or accompanied by a translation certified by a state service or authorised translator. It may be submitted in physical or electronic form and must be transmitted no later than 30 April.

Both files must be updated as at 31 December of each fiscal year and upon the occurrence of a major event, such as a restructuring or substantial transfer pricing modification. Documentation must be retained for a minimum of 10 years and produced upon request by the tax administration.

Defective, insufficient or non-compliant documentation gives rise to a presumption of non-transparency and triggers the application of penalty provisions under the CGI.

NIGERIA: Implementation of Taxpayer Identification system announced

On 18 May 2026, the Revenue Service (NRS) and the Joint Revenue Board (“JRB”) issued a joint public notice announcing the implementation of the Taxpayer Identification (“Tax ID”), in line with the provisions of the Nigeria Tax Administration Act, 2025, which mandate every taxable person in Nigeria obtain a Tax ID.

The Tax ID provides a unified taxpayer identification system giving taxpayers a single tax identity to simplify compliance, improve transparency, enhance revenue assurance and align taxpayer information across all tiers of government.

The joint public notice provides that ministries, departments and agencies, financial institutions and other organizations currently utilising the Tax Identification Number Validation API are notified that the new Tax ID system will replace the existing TIN Validation API.

NIGERIA: 1% Presumptive tax regime for undocumented income gazetted

Nigeria has gazetted the Nigeria Presumptive Tax Regulations, 2026, issued by the Minister of Finance and Coordinating Minister of the Economy. The Regulations, which became publicly available on 26 June 2026 and took effect on 1 January 2026, introduce a 1% presumptive tax on the actual or estimated annual turnover of taxpayers whose income cannot be accurately determined due to inadequate records, including cases involving the deliberate withholding or concealment of information.

However, no presumptive income tax is payable in respect of exempted nano businesses listed in the First Schedule, including quasi-manufacturing, artisan trades, manual and informal service providers, petty retailers, transport and logistics and informal production or processing, where the actual or estimated annual turnover does not exceed NGN12-million. The relevant tax authority may register such persons and issue taxpayer identification numbers where necessary. The Regulations also provide for:

• Introducing a 2% presumptive tax on chargeable gains arising from the disposal of assets, including land, buildings, movable property, shares and intangible property, realized by individuals, unless exempt under the Nigeria Tax Act. The tax must be remitted within 30 days of the earlier of the completion of the transaction or the receipt of consideration;
• Allowing the relevant tax authority, where adequate information is unavailable, to estimate a taxpayer's turnover using a best-of-judgement approach, taking into account factors such as the nature and location of the business, the taxpayer's lifestyle and assets, community intelligence and electronic and cash transaction volumes;
• Taxpayers retaining the right to object to assessments within 30 days and may pursue further review through applicable administrative dispute resolution procedures, including the Office of the Tax Ombud or the Tax Appeal Tribunal; and
• Permitting taxpayers to exit the presumptive tax regime and file self-assessment returns, provided that they notify the relevant tax authority before the statutory filing deadline. Conversely, where a tax authority determines that a taxpayer has begun maintaining adequate records, it may require the taxpayer to transition to the ordinary self-assessment system.

NIGERIA: 1% Stamp duty on government payments discontinued

On 15 June 2026, the Federal Government, through the Office of the Accountant-General of the Federation, has issued a circular directing all Ministries, Departments, and Agencies (“MDAs”) to discontinue the deduction of 1% stamp duty from payments made to contractors, suppliers, vendors and service providers on the basis it is inconsistent with the new stamp duty provisions introduced under the Nigeria Tax Act 2025 (“NTA”).

It further clarifies that:

• Stamp duties will be charged, deducted or remitted only on chargeable instruments and transactions expressly identified in the NTA, rather than on payment transactions. Consequently, MDAs must cease applying this deduction with immediate effect;
• Stamp duty deductions validly made before the commencement of the NTA remain preserved under the Act's savings provisions; and
• Contracts awarded before 1 January 2026 will be governed by the repealed laws, while contracts awarded after that date will be subject to the NTA.

NIGERIA: Transition guidelines for new Tax Acts issued

On 18 June 2926, the Federal Ministry of Finance issued the General Transition Guidelines for the Tax Acts 2025 to facilitate the implementation of Nigeria's new tax framework which came into effect on 1 January 2026. The Guidelines clarify the treatment of tax obligations, transactions, disputes and incentives during the transition from the repealed tax laws to the new regime. Key provisions include:

• Non-retroactivity: the new tax laws do not apply retrospectively. Taxes, penalties, interest, filing obligations and administrative requirements arising before 1 January 2026 remain governed by the repealed laws;
• Pre-commencement liabilities: assessments, audits, investigations, enforcement actions and tax liabilities relating to periods before 1 January 2026 will continue to be administered under the repealed legislation;
• Individuals: employment income earned up to 31 December 2025 remains taxable under the repealed personal income tax regime, while income earned from 1 January 2026 is subject to the new laws;
• Companies: accounting periods ended before 1 January 2026 remain taxable under the repealed corporate tax rules, even where filing or payment obligations arise after commencement. Accounting periods ending on or after 1 January 2026 are subject to the new regime;
• VAT and withholding tax: transactions completed on or before 31 December 2025 remain subject to the repealed laws regardless of when payment is made. Transactions occurring from 1 January 2026 are generally subject to the new legislation;
• Advance payments: where payment was made before 1 January 2026 for a transaction completed after commencement, the tax treatment will generally follow the repealed laws;
• Contracts spanning the transition date: for contracts entered into before but performed after 1 January 2026, the new laws apply only to the portion of the contract performed after commencement;
• Pending disputes and proceedings: tax disputes, objections, appeals and litigation begun before the commencement date will continue under the repealed laws until final determination;
• Tax incentives and exemptions: existing incentives, exemptions and reliefs granted under the repealed laws remain valid until their expiry dates. New and pending applications are to be considered under the new pieces of legislation;
• Records and documentation: taxpayers are required to retain records relating to pre-commencement periods in accordance with the requirements of the repealed laws; and
• Inconsistency: where a tax-related law is inconsistent with the 2025 Acts, the provisions of the new Acts prevail to the extent of the inconsistency.

REPUBLIC OF THE CONGO: Official awareness campaign launched for upcoming e-invoicing obligations

On 16 June 2026, the Ministry of Finance, Budget and Public Portfolio officially launched a national awareness campaign for the Systeme de Facturation électronique Certifiée (“SFEC”), a structural tax reform covering every natural or legal person that supplies, distributes or uses electronic invoicing terminal or software in commercial transactions.

Under the Decree of 30 March 2026, an initial voluntary pilot phase allowed enterprises to test the platform ahead of the implementation deadline. From 1 July 2026, connection to the SFEC platform is a legal obligation for all enterprises.

Companies operating in the Republic of Congo must verify their POS systems, billing software certification status and platform connectivity to ensure full compliance.

RWANDA: New transfer pricing rules published

Through Ministerial Order No. 003/26/10/TC, gazetted on 29 April 2026, Rwanda has published new Transfer Pricing Rules, replacing the 2020 Transfer Pricing Rules which ceased to apply in October 2023 in accordance with the Income Tax Law No. 027/2022 of 20 October 2022.

The new Rules are effective from 29 April 2026 and provide for standard transfer pricing methods, functional and comparability analysis, transfer pricing documentation requirements and contain provisions specific to intra-group services and transactions involving intangibles.

 A new feature under the new Transfer Pricing rules is the framework for advance pricing agreements, which provides that a taxpayer may apply for an advance pricing agreement before entering into one or more controlled transactions with a related party. The validity period for the an advance pricing agreement is three years, subject to renewal upon request by the taxpayer. However, a taxpayer must submit to the tax administration an compliance report for each income tax year of the covered period on the date of filing the income tax return.

SEYCHELLES: Vienna Convention on the Law of Treaties joined

On 29 May 2026, Seychelles deposited its instrument of accession to the UN Vienna Convention on the Law of Treaties (1969). It will enter into force for Seychelles on 28 June 2026.

UGANDA: High Court rules that 30% EBITDA interest limitation applies to net interest

The Uganda High Court recently ruled in the case of Ambitious Construction Company Limited vs Uganda Revenue Authority, High Court Civil Appeal No. 0082 of 2025, that the 30% EBITDA interest limitation under section 25 of the income Tax Act, Cp 338 applies to net interest instead of gross interest.

In the case at hand, Ambitious Construction Company Limited ("ACCL") borrowed money to finance its business operations. Unexpected eventualities resulted in an inability to immediately utilise the borrowed funds. Instead of holding idle cash, ACCL temporarily lent part of the funds to third parties and earned interest income.

For the tax periods 2019-2021, when computing its deductible interest, ACCL applied the 30% EBITDA interest limitation on the net interest cost (interest paid / payable to the lender less the interest earned from the on-lending). The Uganda Revenue Authority (“URA”) disagreed with this approach, arguing that the limitation should, instead, be applied to the gross interest expense without netting off interest earned from the on-lending, and issued additional income tax assessments.

ACCL unsuccessfully objected to the assessments and subsequently filed an application before the Tax Tribunal, arguing that a net interest approach in relation to the 30% EBITDA interest limitation if most appropriate, as it is consistent with the purpose of the statutory provision and the OECD BEPS Action 4 Report which recommends a net interest-based EBITDA ration for deductibility of interest for entities that are part of a group. The URA, on the other hand argued that the Income Tax Act makes not reference to “net interest” and that the OECD Report could not override the clear wording of the Income Tax Act. The Tribunal ruled in favour of the URA.

ACCL filed an appeal before the High Court, which ruled in favour of the taxpayer on the basis that:

• The manifest legislative actions in 2018 and 2019 were primary evidence of Parliament’s intent to domesticate the OECD-BEPS recommendations for interest capping, which recommended a net interest approach;
• Section 25(3) of the Income Tax Act was meant to domesticate the EBITDA-based fixed ratio rule recommended by the OECD BEPS Action 4 Report. The Court noted that the legislative actions clearly showed an intension to implement the net interest based fixed ratio rule; and
• Section 25 (3) of the Income Tax Act must be interpreted in a manner consistent with the recommendations of the OECD BEPS Action 4 Report. In this regard, the Court reasoned that in arrangements where a taxpayer borrows funds and on-lends to generate taxable interest income, the deductible interest subject to the 30% EBITDA limitation must be the net interest cost.

Having found that the assessment was premised on a wrong interpretation and application of the law, the attendant tax liability was set aside.

ZAMBIA: Investment Protection Agreement with Japan enters into force

The Japan - Zambia Investment Protection Agreement (2025) will enter into force on 30 July 2026 and shall be valid for 10 years. Its shall continue to be in force unless either country decides to terminate it.

ZAMBIA: Suspension of fuel excise duty and zero-rated VAT extended for 90 Days

On 1 July 2026, the government announced a further 90-day extension of both the temporary suspension of excise duty and the zero-rating of VAT on petrol and diesel imports, aimed at mitigating surging global oil prices driven by geopolitical conflicts and to maintain local economic stability.

The extension is executed via Statutory Instrument No. 60 of 2026, enacted under the Customs and Excise Act and Statutory Instrument No. 61 of 2026, issued under the VAT, and will run from 1 July 2026 to 30 September 2026.

ZIMBABWE: Guidance on China's zero tariff on exports issued

On 24 June 2026, the Zimbabwe Revenue Authority (ZIMRA) issued guidance to exporters on the requirements for accessing China's zero-tariff treatment for eligible goods exported from Zimbabwe to China.

Under the arrangement, qualifying Zimbabwean products may enter China free from tariffs and duties from 1 May 2026 until 30 April 2028. This applies to specified products originating in Zimbabwe, including selected agricultural products, minerals and manufactured products. To qualify for duty-free entry into China:

• Goods must either be wholly obtained in Zimbabwe or meet the prescribed origin criteria demonstrating sufficient Zimbabwean content;
• Exporters wishing to benefit from the arrangement must register through the Zimbabwe electronic single window (ZESW) platform and obtain a certificate of origin issued through ZimTrade;
• Exporters must comply with all customs procedures and China's applicable sanitary, phytosanitary and quality standards;
• Goods should be shipped directly from Zimbabwe to China. Where goods transit through a third country, exporters must be able to demonstrate that the goods remained under customs control and were not altered during transit; and
• Exporters must maintain supporting documentation relating to exports under the arrangement for a minimum period of six years and make such records available upon request by the relevant authorities.