Africa Regulatory ENSight - October 2019

African nations are implementing sweeping tax reforms across multiple jurisdictions, from Angola's supplementary petroleum incentives and Nigeria's virtual asset taxation framework to Mauritius's digital marketplace VAT rules and the Democratic Republic of the Congo's mining royalty adjustments. These coordinated changes reflect a continent-wide effort to modernize revenue collection, expand digital taxation, and strengthen compliance mechanisms.

This comprehensive update covers significant tax and regulatory developments across 30 African jurisdictions during mid-2026, including Angola's new oil block incentives and unified Personal Income Tax Code, Botswana's major tax rate increases and transfer pricing regulations, Kenya's Finance Act 2026 with mortgage interest relief expansion, Nigeria's implementation of the unified Taxpayer Identification system and presumptive tax regime, and Rwanda's new transfer pricing rules framework. The bulletin exami

According to the OECD's Revenue Statistics in Africa 2025 report released in December 2025, tax revenues as a percentage of GDP have increased in 24 countries...

The Financial Surveillance Department of the South African Reserve Bank (“FinSurv”) recently published a suite of draft exchange control circulars for comment, giving effect to the Minister of Finance’s 2026 Budget Speech announcements...

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.

South Africa's mining sector operates in a complex tax, regulatory and ESG environment requiring careful management of specialist income tax rules, mineral royalties, VAT, customs obligations...

A South African High Court has ruled on the lawfulness of account freezing by banks based on fraud suspicions and affirmed SARS's authority to issue third-party notices under section 179 of the Tax Administration Act. The case arose after a close corporation fraudulently claimed a VAT refund of R3.28 million, transferred R900,000 to an individual's account, prompting the bank to freeze the account and SARS to pursue recovery through a third-party notice.

Section 42 of the Income Tax Act, Act 58 of 1962 (herein the "ITA"), allows for the tax implications, normally associated with a disposal of assets...

South Africa's diesel refund scheme has long provided fiscal relief to mining operations, but its legislative framework struggles to accommodate modern contractual arrangements like wet contracts and joint ventures. Recent Supreme Court of Appeal judgments and 2022 amendments are reshaping how mining companies can access these vital refunds, though significant gaps remain between commercial reality and legal requirements.

The South African Revenue Service has launched a modernised Diesel Refund System on eFiling, fundamentally changing how businesses register for and manage diesel refund claims. This digital transformation introduces a standalone platform that replaces the VAT-linked model, requiring all existing users to reregister and establish electronic supplier relationships. The transition will occur in phases, with standalone claims functionality expected in 2027 while the current system continues operating in paralle