Africa: Tax

As artificial intelligence increasingly performs tasks once carried out by human workers, governments face a fundamental challenge: tax systems designed around employment-based revenue are under pressure. With more economic value flowing to technology and capital rather than through traditional payroll structures, policymakers must confront difficult questions about how automation should be taxed and whether current incentives inadvertently encourage workforce reduction.

This issue of ENS' tax in brief provides a comprehensive snapshot of recent tax developments in South Africa, covering significant Supreme Court and High Court judgments on taxpayer representation and customs seizures, legislative amendments to customs rules and fuel levies, SARS publications on compliance requirements, and updates on exchange control regulations including crypto asset treatment.

Nigeria's tax landscape has undergone a fundamental shift with the enactment of the Nigeria Tax Act, 2025, which consolidates the country's core federal tax laws into a single unified framework. This reform introduces significant changes to how mergers and acquisitions are structured, priced, and executed, including the integration of capital gains into the income tax regime, revised exemptions for share disposals, and the introduction of taxation for indirect transfers.

Estate planning extends far beyond drafting a valid Will. This article examines the critical but often overlooked issue of estate liquidity—the availability of cash to settle taxes, debts, and administration costs—and explains why asset-rich estates can still face serious financial challenges during administration.

Between Wednesday and Thursday, 7th and 8th of May 2025, the Senate passed all four of President Bola Ahmed Tinubu's proposed tax reform bills for the next step of enactment into laws.

In 2024, the Nigeria government took a bold step to overhaul its tax system by proposing significant reforms aimed at increasing revenue generation, reducing economic inequalities, and improving compliance.

The African Tax Administration Forum and OECD have concluded transfer pricing workshops for Francophone tax officials, while multiple African nations implement significant tax reforms including VAT changes, e-invoicing requirements, and new compliance measures. From Kenya's reduced petroleum VAT rates to Liberia's comprehensive tax amendments and Uganda's proposed alternative minimum tax, these developments reflect a continent-wide effort to modernize tax administration and enhance revenue collection.

Issue 164 of ENS' tax in brief, a snapshot of the latest tax developments in South Africa.

In recent years, transfer pricing (TP) has emerged as a significant concern for multinational enterprises (MNEs) operating in Nigeria. With the Nigeria Revenue Service (NRS) (formerly Federal Inland Revenue Service) intensifying efforts to generate revenue through taxation, taxpayers face heightened scrutiny, prolonged audits, and increasing risk of double taxation.

This article examines Nigeria's Free Trade Zone (FTZ) regime, focusing on the legal framework, incentives, and investment opportunities available to local and foreign investors.

This article examines the evolving regulatory and compliance landscape governing Nigeria’s Free Trade Zones (“FTZs”), with particular focus on the roles of the Nigeria Export Processing Zones Authority (“NEPZA”), the Oil and Gas Free Zones Authority (“OGFZA”), and other embedded regulators operating within the zones

A landmark High Court ruling in Uganda has fundamentally altered how the 30% tax deposit requirement applies when taxpayers challenge assessments before the Tax Appeals Tribunal.