ARTICLE
17 August 2026

Africa Tax In Brief

E
ENS

Contributor

ENS is an independent law firm with over 200 years of experience. The firm has over 600 practitioners in 14 offices on the continent, in Ghana, Mauritius, Namibia, Rwanda, South Africa, Tanzania and Uganda.
This comprehensive briefing covers recent tax law changes, regulatory updates, and compliance requirements across multiple African jurisdictions including Benin, Botswana, Burkina Faso, Burundi, and many others. The updates span corporate tax reforms, VAT amendments, withholding tax changes, and new administrative procedures affecting businesses operating throughout the continent.
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BENIN: 2026 Amending Finance Law promulgated by the President

Law No. 2026-10 of 24 June 2026, the amending finance law for the 2026 financial year, was adopted by the National Assembly on 19 June 2026 and promulgated by the President on 24 June 2026. Significant amendments include:

Corporate tax

  • Taxing capital gains on the disposal of securities of enterprises established in Benin regardless of the residence of the transferor or transferee;
  • Applying the Impôt sur le Revenu des Capitaux Mobiliers (Income Tax on Movable Capital, IRCM) to retained undistributed profits, whether capitalised or not, where profits are not reinvested within three years after the year in which they were realised. The tax is computed on cumulative undistributed distributable profits after the relevant deductions and must be paid by 31 March following the expiry of the three-year period;
  • Allowing companies with existing undistributed and non-reinvested profits before the law entered into force to regularise their position by 31 December 2026, at a reduced tax rate of 7.5% instead of the standard rate of 15%. After that date, the ordinary rate will apply; and
  • Introducing a withholding tax, borne by the platform operator, on income from furnished lettings and short- or long-term accommodation arranged through digital platforms, excluding hotel accommodation.

Tax administration

  • Reducing the taxpayer's period to reply to a request for information, clarification or justification, or to a proposed adjustment from 30 to 15 days, with no response deemed to constitute tacit acceptance;
  • Reducing the deadline for issuing a notice of adjustment from two months to 15 days following an accounting audit, and from 15 to eight days following a spot check;
  • Extending the time period granted to administration to confirm the tax after the taxpayer's reply from two months to one month, extendable by 15 days;
  • Capping on-site audits at two months for enterprises with declared annual turnover up to CFA2-billion, and at four months otherwise, extendable by a further four months;
  • Granting audit notices sent electronically the same legal effect as written notices, without requiring a signature; and
  • Requiring prior notice of a business cessation or transfer to be given three months in advance, together with an up-to-date tax position.

BOTSWANA: Updated PAYE guidance on valuation of employee benefits issued

On 2 July 2026, the Botswana Unified Revenue Service (“BURS”) issued updated pay-as-you-earn (“PAYE”) Tax Tables and Guidance Notes for employees’ income. The guidance, which is effective from 1 July 2026, sets out revised rules for the valuation of non-cash employment benefits in accordance with the Income Tax Act and the Income Tax Regulations, and include the following rules:

  • Non-cash benefits must be included in an employee's employment income in the pay period in which the benefit is provided. Covered benefits include debt waivers, employer-provided housing, school fees, motor vehicles, utilities, concessional loans and other residual benefits;
  • Housing benefits are valued using different methods depending on whether the property is leased, rateable, or non-rateable. Where an employer leases accommodation, the taxable benefit equals the rent paid by the employer. For employer-owned rateable properties, the annual benefit is generally 10% of the property's rateable value, while non-rateable properties are generally valued at 8% of the property's capital value, subject to prescribed valuation rules;
  • Employer-paid school fees remain taxable based on the highest of the fees paid, reimbursed, or the market value of the benefit;
  • Employer-provided motor vehicles used wholly or partly for private purposes are valued at 10% of the acquisition cost (or fair market value for leased vehicles), apportioned over the relevant pay-period. Maintenance and running costs relating to private use are included in the benefit;
  • Utilities paid by employers, including telephone, water, electricity and internet services continue to constitute taxable benefits;
  • Interest-free and low-interest employee loans are taxable based on the difference between the interest charged and the interest that would have been payable using the Bank of Botswana Monetary Policy Rate prevailing on 1 July of the relevant tax year;
  • Benefits not specifically addressed elsewhere, are generally valued at the higher of the employer's cost, any reimbursement made by the employer or the market value of the benefit. Special valuation rules apply to subsidised air travel provided by airline employers; and
  • In respect of retrospective employment income paid as lump sums, amounts relating to periods of eight years or less are allocated to the tax years in which they accrued, while payments relating to longer periods may be apportioned by the Commissioner General on a reasonable basis.

BOTSWANA: Tax laws Botswana re-enacted and amended effective 1 July 2026

In a Public Notice dated 1 July 2026 and published on 2 July 2026, the BURS has announced the re-enactment and amendment of the Income Tax Act, Value Added Tax (“VAT”) Act, Customs Act and the newly enacted Tax Administration Act. The Acts became effective on 1 July 2026 and introduce changes that had been proposed in the Tax Amendment Bills, including:

Income tax

  • Increasing the resident corporate income tax rate from 22% to 24.5% and reducing the non-resident corporate income tax rate from 30% to 24.5%;
  • Introducing a simplified income tax regime for qualifying small businesses with annual turnover below BWP1-million;
  • Introducing new source taxation rules;
  • Introducing permanent establishment rules;
  • Increasing the depreciation allowances for mining companies and motor vehicles;
  • Introducing tax on repatriated profits for non-residents;
  • Imposing a 3% withholding tax on insurance premiums paid to non-resident insurers;
  • Abolishing withholding tax on livestock sold for slaughter;
  • Harmonising taxation rules for mutual associations;
  • Increasing the top personal income tax rate from 25% to 27.5% for annual taxable income exceeding BWP400 000;
  • Requiring employees of specified international organisations and diplomatic missions to withhold tax on their payments, where the employer does not fulfil its withholding obligations; and
  • Requiring employers to withhold PAYE using the new tax tables and regularise the withholding by 30 September 2026.

VAT

  • Requiring non-resident suppliers of remote services to register for, charge and remit VAT;
  • Requiring registered taxpayers to account for reverse-charge VAT on imported services;
  • Extending the period for claiming input VAT from four months to 12 months;
  • Requiring excess input tax credits to be carried forward for four months before becoming refundable;
  • Revising the list of zero-rated food items; and
  • Requiring taxpayers to register for VAT under the new rules by 31 July 2026, while existing taxpayers who are VAT registered to charge VAT under the new legislation from 1 August 2026.

Tax Administration

  • Providing for the registration of tax agents;
  • Introducing a binding tax ruling system;
  • Establishing a tax tribunal;
  • Introducing a voluntary disclosure programme;
  • Harmonising the record retention period for income tax and VAT to eight years;
  • Harmonising tax payment deadlines, including:
    • VAT returns and payments by the 28th day of the month following the end of the tax period;
    • self-assessment tax payments by the 28th day of the month following the end of the quarter;
    • withholding tax returns and payments by the 14th day of the month following the month of withholding;
    • annual withholding tax returns within 28 days after the end of the tax year; and
    • payment of capital gains tax within 28 days of disposal of an asset; and

BURKINA FASO: Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (CbC MCAA) signed 

Burkina Faso joined the Multilateral Competent Authority Agreement on Automatic Exchange of Country-by-Country Reports (2016) (“CbC MCAA”) on 29 June 2026. As of 29 July 2026, the CbC MCAA has been signed by 118 jurisdictions.

BURKINA FASO: Draft 2026 Amending Finance Law approved

In an official announcement published on its website on 23 July 2026, Burkina Faso's Council of Ministers approved a draft amending finance law for 2026. The law has been transmitted to the Transitional Legislative Assembly for examination and vote.

Further details on the fiscal provisions will be reported once the law is enacted and published.

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

Through Circular No.2026-02020/MEF/SG/DGI, issued on 29 June 2026, Burkina Faso has suspended the local filing obligation for country-by-country (“CbC”) reports for companies operating in the country for fiscal years 2023, 2024 and 2025 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 commencing from 1 January 2023.

BURUNDI: Finance Law 2926/2027 published

The Burundi Revenue Office has published the Finance Law for 2026/2027(Law No. 1/10 of 30 June 2026), as well as the Table of Tax Measures, which came into effect on 1 July 2026. Significant amendments include:

  • Introducing reduced corporate tax rates for companies that publicly list their shares on an approved market in Burundi, with the applicable tax rate based on the proportion of capital listed as follows:
    • 28% when a company offers at least 20% of its share capital to the public;
    • 25% when a company offers at least 30% of its share capital to the public; and
    • 20% when a company offers at least 40% of its share capital to the public;
  • Introducing new interest deduction limitations, including:
    • the deduction of interest paid on loans and advances received from related persons, which is limited to 30% of taxable profit determined before the deduction of interest paid on such loans and advances;
    • interest accrued between related parties but not paid is non-deductible; and
    • the interest rate for loans and advances with related parties must not be higher than the average local market rate;
  • Expanding rules restricting the retention of net profits to prohibit a company from allocating its net profit to capital increases, retained earnings, or reserves for two consecutive financial years, in which case the net profit is treated as deemed dividend subject to 15% withholding tax. 100% of net profit is deemed to be distributed 30 days after the annual return deadline if there is no formal record (minutes) on the allocation of net profit;
  • Expanding the tax base for the collection of rental income tax to include income from the renting of buildings and land (previously just buildings);
  • Introducing a 4% tax payable by employers in respect of workers outside Burundi, which is levied on the gross annual salary of such workers and is due by 31 March of each year;
  • Extending the income tax exemption on interest from treasury bills and bonds to gains realised from the sale of such treasury securities on the secondary market;
  • Introducing a regional integration levy equal of 2% of the customs value of imports originating outside the East African Union countries, with the exception of petroleum products, imports intended for the official use of diplomatic missions and specialised agencies of the United Nations, the Presidency of Burundi, and the defence and police sectors, as well as donations made to the State by assistance organisations or development partners;
  • Introducing an exemption from all import duties, taxes, and fees for electric vehicles, an exemption from consumption tax and import VAT for hybrid vehicles, and a VAT exemption on the import and local sale of spare parts intended exclusively for electric and hybrid vehicles, as well as assembly and repair services for such vehicles;
  • Revising the thresholds for mandatory and optional VAT registration:
    • mandatory registration if taxable turnover exceeds BIF25-million during an accounting year;
    • optional registration if taxable turnover is at least BIF5-million during an accounting year;
    • mandatory registration if local purchases and/or imports are at least BIF50-million during an accounting year;
    • mandatory registration for taxpayers with a stock of raw materials, finished or semi-finished products or goods with a value exceeding BIF50-million; and
  • Introducing a three-month time limit for the Minister of Finance to respond to appeals contesting decisions of the Joint Appeal Committee, along with a rule that if a decision is not made within the prescribed limit, the appeal will be deemed to be well founded and the disputed tax shall be revoked Appeals may be made within 60 days of a committee decision, whereas there was previously no limit for the Minister to respond.

Cote d’Ivoire: VAT on inputs for fertilizer manufacturing and packaging suspended

The Directorate General of Taxes (Direction Générale des Impôts, DGI) in Official Notice No. 03986/MEFB/DGI/DGA-CISS/DLCD-SDL/gr/tc/07-2026, issued on 22 July 2026 introduced the suspension of VAT on inputs used in the manufacturing of fertilizers and on packaging materials used for their conditioning with effect from 1 July 2026 until 31 December 2026.

Before the suspension, the relevant goods were subject to a reduced 9% VAT rate introduced by an ordinance effective from 17 January 2026. Suppliers will therefore not pursue VAT payments during the suspension period. However, VAT already invoiced and collected prior to the suspension must be remitted to the tax administration under the standard rules.

ESWATINI: Framework for electronic fiscal documents under VAT Law introduced

Through Legal Notice No. 111 of 2026, published on 20 July 2026, the Minister of Finance has issued the VAT Act (Amendment of Third Schedule) Notice 2026, amending the Third Schedule to the VAT Act, 2011, to establish a legal framework for electronic fiscal documents. The Notice, which comes into force upon its publication in the Official Gazette:

  • Authorises the Commissioner General of Eswatini Revenue Service to prescribe technical and operational requirements for those documents;
  • Permits tax invoices, fiscal receipts, credit notes and debit notes to be issued electronically through an electronic fiscal device or another electronic system authorised by the Commissioner General;
  • Authorises the Commissioner General to prescribe the particulars, identifiers, security features, digital signatures, verification codes, fiscal data or any other information that electronic fiscal documents must contain;
  • Authorises the Commissioner General to prescribe the form and manner in which electronic fiscal documents and related fiscal data must be issued, stored, submitted and verified;
  • Authorises the Commissioner General to require electronic fiscal documents and related fiscal data to be generated, secured, stored or transmitted through an electronic fiscal device or any other authorised electronic system;
  • Provides that electronic tax invoices, fiscal receipts, credit notes and debit notes issued in accordance with the prescribed requirements are valid for purposes of the Act; and
  • Introduces definitions of the following terms for purposes of the electronic fiscal document framework.

GHANA: 2026 Mid-Year Fiscal Policy Review presented to Parliament

The Minister of Finance presented the 2026 Mid-Year Fiscal Policy Review to Parliament on 23 July 2026, providing an update on the implementation of the government's 2026 fiscal policy measures and outlining further reforms aimed at modernising tax administration.

The Minister reported that the implementation of the previously announced VAT reforms introduced under the VAT (Amendment) Act 2025 is currently in progress and includes:

  • The abolition of the COVID-19 health recovery levy, electronic transfer levy and emissions levy;
  • The decoupling of the Ghana Education Trust Fund (GETFund) levy and the National Health Insurance Levy (NHL) from the VAT base, making both eligible for input tax deductions;
  • The reduction of the effective VAT rate from 21.9% to 20%;
  • The abolition of VAT on mineral reconnaissance and prospecting activities;
  • An increase in the VAT registration threshold from GHS200 000 to GHS750 000; and
  • The extension of the zero-rating for locally manufactured textiles until 2028.

The Minister also announced the following updates:

  • Regulations to implement the VAT reforms enacted under Act 1151 are expected to be issued in 2027. In the interim, the Ghana Revenue Authority will continue to issue administrative guidelines and practice notes;
  • The government is awaiting necessary regulatory approvals for the nationwide rollout of the digital system for collecting VAT from non-resident digital platforms following a successful pilot;
  • The government is rolling out fiscal electronic devices to improve VAT compliance and monitor taxable transactions; and
  • The introduction of a VAT Reward Scheme under which consumers who request and obtain valid VAT invoices will be eligible for periodic rewards.

KENYA: Reduced VAT rate on certain fuels temporarily extended

The Kenya Revenue Authority has published the VAT (Amendment of Rate of Tax) Order 2026, which extends the temporary reduction in the VAT rate from 16% to 8% on:

  • Motor Spirit (gasoline) premium;
  • Illuminating Kerosene; and
  • Gas Oil (automotive, light, amber for high-speed engines).

The reduction was previously applied for a period of 90 days, beginning 15 April 2026. The Order provides that the reduced rate continues to apply from 15 July to 14 October 2026.

LIBERIA: Mandatory three-year review for tax incentives and holidays announced

At a press briefing on 7 July 2026, the government launched the Tax Incentive and Expenditure Management Act of 2025, which introduces a mandatory three-year review clause for tax incentives and holidays. The Act amends the Liberia Revenue Code and provides for the following key tax measures:

  • Introducing a comprehensive legal framework for the classification, review and rationalisation of tax expenditures;
  • Establishing rules for improving oversight and management of tax incentives, corporate exemptions, investment waivers and concessionary arrangements granted to businesses and individuals;
  • Limiting indefinite tax waivers and capping non-essential duty exemptions for imported goods that are available from domestic sources; and
  • Requiring the Ministry of Finance and Development Planning and the Liberia Revenue Authority to regularly publish reports on tax expenditures, enabling the government to monitor the fiscal cost of incentives and concessions more effectively.

MADAGASCAR: Amending Finance Law 2026 enacted

The Amending Finance Law 2026 was adopted by the National Assembly on 22 June 2026. Following review by the High Constitutional Court on 15 July 2026, it was promulgated as Law No. 2026-004 on 16 July 2026. Significant amendments include:

Direct taxation

  • Cooperative companies becoming subject to corporate income tax (Impôt sur les revenus, IR), irrespective of their annual turnover, while their members remain taxable individually under the ordinary income tax regime;
  • Expressly including interest received by credit institutions from lending activities in the taxable business income;
  • Subjecting interest received by non-resident banks and credit institutions from their lending activities to a 10% withholding tax, with an exclusion for interest on loans intended to finance investment in Madagascar;
  • Allowing tax losses of an absorbed company to be transferred to the absorbing company, subject to prior authorisation from the tax administration;
  • Extending the scope of tax on income from movable capital tax (Impôt sur les revenus des capitaux mobiliers, IRCM) to capital gains arising from the disposal of securities by resident and non-resident individuals and legal entities; and
  • Suspending the application of the Tax on Motor Vehicles (Taxe sur les véhicules à moteur, TVM) introduced under the Finance Law 2026 until further notice.

Indirect taxation

  • Exempting interest arising from loan and financing operations from VAT. Previously, a 20% VAT rate introduced by the 2025 Finance Law applied;
  • Subjecting imports and domestic sales of luxury rice, previously exempt from VAT, to the reduced VAT rate of 5%;
  • Subjecting imports and domestic sales of hybrid vehicles and kerosene, previously exempt from VAT, to the standard 20% VAT rate;
  • Repealing the VAT exemptions previously granted to transactions benefiting government-recognised public-interest foundations. Input VAT incurred on purchases of goods donated to these foundations is no longer deductible; and
  • As from 1 January 2027, increasing stamp duty on visas from MGA270 000 to MGA692 500 depending on the duration of the stay (previously ranging between MGA65 000 and MGA487 500).

Tax Administration

  • Extending the deadline for responding to requests issued by the tax administration from eight days to 30 days;
  • Requiring a collection order to accompany every land tax assessment notice (previously, it was only required for property tax on developed land assessment notices); and
  • Strengthening the penalty regime for non-compliance with the beneficial ownership and transfer pricing provisions by introducing administrative fines of up to 5% of the taxpayer's annual turnover, subject to a minimum penalty of MGA50-million.

MAURITIUS: Promulgation of Income Tax (Qualified Domestic Minimum Top-Up Tax) Regulations 2026 agreed to by Cabinet

In a meeting on 17 July 2026, Cabinet agreed to the promulgation of the Income Tax (Qualified Domestic Minimum Top-up Tax) Regulations 2026 which supplement the legislative framework governing the qualified domestic minimum top-up tax (“QDMTT”) introduced with effect from 1 July 2025.

According to the Cabinet decision, the Regulations provide the detailed rules necessary for the effective implementation of the QDMTT framework, including prescribing the methodology for computing the jurisdictional effective tax rate, the determination and application of the domestic top-up tax, and the categories of entities excluded from the application of the QDMTT.

The Regulations are intended to provide greater certainty regarding the operation of the domestic minimum tax regime and facilitate the implementation of Mauritius' commitments under the OECD/G20 inclusive framework on base erosion and profit shifting.

MAURITIUS: Tax agent registration mandated from June 2026

On 1 July 2026, the Mauritius Revenue Authority (“MRA”) issued a communication informing the public of mandatory registration for tax agents, effective from 30 June 2026, in accordance with the MRA Act, 2004.

The communication outlines the registration procedure, the registration of nominees by entities registered as tax agents, the processing of applications and transitional arrangements, and provides that:

  • Only tax agents registered with the MRA may prepare or submit tax returns or statements on behalf of taxpayers and represent taxpayers before the MRA, the alternative tax dispute resolution panel or the revenue tribunal;
  • A person qualifies for registration as a tax agent if they are a Mauritian citizen and satisfy one of the prescribed professional or academic criteria, including being a member of the Mauritius Institute of Professional Accountants (“MIPA”), a legal practitioner, or having at least three years' experience in dealing with accounting or tax matters while employed by a MIPA member, or holding a degree in taxation, accountancy, economics, business management, or another related field acceptable to the MRA; and
  • In the case of an entity, it must be registered with MIPA as a public accountant.

NAMIBIA & TANZANIA: Peer Review Reports on Transparency and Exchange of Information on Request published by Global Forum

On 29 July 2026, the Global Forum on Transparency and Exchange of Information for Tax Purposes published new peer review reports for inter alia Namibia and Tanzania, assessing the implementation of the international standards for transparency and exchange of information on request (EOIR) in each jurisdiction.

Namibia received a rating of "Largely Compliant" for this first full assessment, due to key elements such as timely exchanges and a sound legal and regulatory framework. The supervision of entities, in respect of their tax and beneficial ownership reporting requirements, and ensuring confidentiality of information have been noted as areas for improvement.

Tanzania also underwent its first full assessment and received a rating of "Largely Compliant". Due to a small treaty network, Tanzania has had limited experience in exchanges, but it maintains the necessary legal and regulatory framework. However, further implementation is needed regarding supervisory and oversight mechanisms.

By 29 July 2026, 135 jurisdictions have been fully reviewed by the Global Forum, with 91% of these jurisdictions receiving a "Compliant" or "Largely Compliant" rating.

NIGER: Tax on money deposits and transfers postponed to 1 October 2026

In Official Notice No. 001632/ME/F/SG/DGI/DL/CFI of 2 July 2026 the Minister of Economy and Finance announced the further postponement of the application of the tax on money deposits and transfers (taxe sur les dépôts et transferts d'argent) introduced by Finance Law 2026. The tax, previously applicable from 1 July 2026, will now take effect from 1 October 2026.

The Ministry of Economy and Finance had initially postponed the application of the tax due to IT requirements for processing transactions, interfacing and collecting the tax not been completed.

NIGERIA: E-Invoicing compliance monitoring for large taxpayers commenced

In a public notice published on X on 20 July 2026, the Nigeria Revenue Service (“NRS”) announced that it has begun monitoring large taxpayers' compliance with the national e-invoicing and electronic fiscal system (“EFS”) regime and has fixed 31 July 2026 as the deadline for the commencement of compliance and full implementation. Large taxpayers are defined as businesses with an annual gross turnover of at least NGN5-billion.

Taxpayers that have not yet commenced or completed the implementation process are required to achieve full compliance with the national EFS requirements on or before 31 July 2026. Non-compliance after the implementation date would attract regulatory and enforcement action under the applicable tax laws.

Full compliance requires affected taxpayers to:

  • Complete onboarding onto the NRS Merchant Buyer Solution (MBS) system;
  • Integrate their internal systems through approved access point providers, systems integrators or both;
  • Complete the prescribed validation and testing;
  • Commence active transmission of invoices to the NRS platform in accordance with the approved standards and guidelines; and
  • Accept from suppliers only compliant electronic invoices bearing valid invoice reference numbers.

REPUBLIC OF THE CONGO: National online public revenue payment platform launched

In official press release No. 2242/MFBPP-CAB, issued on 28 July 2026, the Ministry of Finance, Budget and Public Portfolio has launched FOUTA, a national platform for the online payment of public revenue, effective from 3 August 2026.

From that date, taxpayers may pay their taxes, duties and customs duties online, by bank transfer or mobile payment, after filing their returns electronically through the E-TAX and/or SYDONIA systems. Upon completion of the payment process, an electronic receipt issued by the Public Treasury will be generated.

REPUBLIC OF THE CONGO: Amending Finance Law 2026 adopted by Parliament

On 23 July 2026, the National Assembly and Senate adopted the Amending Finance Law 2026 unanimously and without amendment.

The Law pursues the objectives of the Initial Finance Law, including consolidating public revenue by reducing tax exemptions, digitalising tax processes and optimising revenue from natural resources.

SENEGAL: VAT exemption for agricultural equipment and services introduced

Through Joint Order No. 019972 of 17 July 2026, signed jointly by the ministers responsible for finance and agriculture, Senegal has exempted specified agricultural equipment, facilities and services from VAT. The exemption covers listed equipment and facilities, whether imported or produced locally, as well as listed agricultural services. It also converts VAT suspended on qualifying acquisitions made under approved investment programmes into an exemption by operation of law from the date on which the commencement of operations is officially notified.

The annex covers:

  • Equipment used for soil preparation, sowing and fertilisation, irrigation, harvesting and post-harvest activities, horticulture, poultry farming and livestock production; and
  • Services such as land clearing, mechanised farming, drainage and irrigation works, phytosanitary treatments, veterinary services, technical studies and agricultural training.

For imports, the customs administration must identify the relevant tariff headings and configure its systems to grant the exemption directly. For domestic supplies, beneficiaries must complete the applicable VAT exemption approval formalities.

The measure is intended to reduce agricultural investment costs, improve the competitiveness of agricultural businesses and support the modernisation of the sector.

TANZANIA: Finance Act 2026 enacted

The Finance Act 2026 was enacted on 30 June 2026 and contains the measures for the 2026/2027 Budget. Significant amendments, which are effective from 1 July 2026, include:

Corporate tax

  • Increasing the upper turnover threshold for the presumptive tax regime from TZS100-million to TZS200-million, along with the revision of the brackets/rates;
  • Introducing a 12-month income tax holiday for newly registered taxpayers operating under the presumptive tax regime, which commences from the date the taxpayer identification number (TIN) is obtained for purposes of commencing a business;
  • Expanding the scope of the 2% single instalment tax on the sale of forest produce to include natural varnish, including latex, resin, sap, and gum, in addition to timber, logs, mirunda, and poles;
  • Reducing the basis for the taxation of a percentage of retained earnings that remain undistributed after 12 months (treated as a deemed distribution), so that tax applies on 15% of retained earnings instead of 30%, along with specific exemptions for:
    • companies listed on the Dar es Salaam Stock Exchange;
    • financial institutions;
    • insurance companies; and
    • mining companies that have entered into a framework agreement with the government;
  • Increasing the tax on non-resident digital service providers from 2% to 3% of the gross payment received;
  • Expanding the definition of electronic services to include any other service of a similar nature delivered through the Internet or a telecommunications network; and
  • Introducing new rules on the treatment of gains on the transfer assets between related parties, to ensure that exempt transfers between related parties do not result in a step-up of the cost base of an asset.

VAT

  • Introducing new provisions to treat a digital intermediary (operator) as the deemed supplier for VAT purposes when electronic services are supplied to unregistered persons through online intermediation services or any other digital marketplace;
  • Introducing new and extended VAT exemptions, including for:
    • imported electric vehicle charging stations by licensed providers;
    • imported liquefied petroleum gas (LPG) smart meters by a distributor;
    • imported paper for printing boarding passes;
    • imported and locally produced dairy packaging materials;
    • turbo jets, turbo-propellers, gas turbines, and new pneumatic rubber tires for aircraft;
    • locally manufactured fishing nets (exemption got imported nets removed);
    • polyester fishing yarn used exclusively for the manufacture of fishing nets;
    • locally manufactured garments made from locally grown cotton (until 30 June 2027); and
    • edible oil produced locally using locally produced seeds (extended to 30 June 2027);
  • Amending the VAT withholding rules to clarify that withholding agents are required to withhold:
    • 3% VAT on the supply of goods, with the balance of 15% VAT paid to the supplier; and
    • 6% VAT on the supply of services, with the balance of 12% VAT paid to the supplier;
  • Introducing a rule that where a supply has both elements of goods and services (i.e., mixed supply), the taxable value subject to withholding shall be apportioned in a ratio of 3:2 for goods and services, respectively;
  • Withdrawing the planned repeal of the VAT deferment regime for specified imported capital goods, allowing the deferment regime to continue beyond 30 June 2026; and
  • Introducing provisions allowing the government to grant income tax and VAT exemptions to mining companies holding mining or special mining licenses that have entered into a framework agreement with the government for a mining project in which the Government holds an ownership interest.

Administration

  • Changing the penalty for adjustments for non-arm's length transactions to 30% of the amount of the adjustment resulting from a transaction conducted in a manner inconsistent with the arms’ length principle or 100% of the tax shortfall, whichever amount is greater (previously just 100% of the tax shortfall);
  • Introducing a new penalty for false tax records, which provides that the making of a false or incorrect entry in any material particular in a book, record, register, or electronic system is an offense subject to a penalty equal to twice the amount of tax evaded; and
  • Amending the tax appeal settlement procedures, including an extension of the period within which taxpayers and the Tanzania Revenue Authority (TRA) may amicably settle a pending tax appeal from 60 days to 90 days from the date the Tax Revenue Appeals Board (TRAB) or the Tax Revenue Appeals Tribunal (TRAT) issues an order permitting the parties to pursue an amicable settlement, along with the possibility of a further 30-day extension if unable to finalise a settlement within the 90-day period.

UGANDA: Proposed tax exemption for casino winnings rejected by President

On 14 July 2026, Uganda's President has returned the Income Tax and Excise Duty Amendment Bills 2026 to the parliament, without assent, rejecting proposed amendments that would have exempted casino winnings from withholding tax and increased excise duty on plastics.

Regarding the Income Tax (Amendment) Bill, 2026, the President opposed a proposed withholding tax exemption for winnings from land-based casinos, arguing that the exemption could encourage tax avoidance and create unequal treatment between land-based casinos and online gaming operators. He recommended applying withholding tax uniformly to betting and gaming winnings, while retaining the exemption for national lottery winnings.

Regarding the Excise Duty (Amendment) Bill, 2026, the President rejected the proposed increase in excise duty on plastics used to manufacture single-use plastic products. He warned that the increase could adversely affect manufacturers, particularly because Uganda lacks readily available alternatives to plastic packaging. The President recommended retaining the existing rate of 2.5% or USD70 per tonne pending further study.

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.

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