International Company Tax Developments and Some Reflections on Ways Forward for the African Continent

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The article comments on the contribution in this edition entitled ‘Unilateral Digital Services Tax in Africa; Legislative Challenges and Opportunities’. The current article also serves as an independent reflection on contemporary developments in company taxation and potential ways forward in this regard for the African continent. With a view to submitting suggestions that could cater to the needs and revenue mobilization interests of African countries and – building on the observations of the commented paper’s author – the current article proposes some suggestions for potential tax policy approaches for Africa. These are based on securing two objectives: (1) maintain and/or attract investment while (2) devising ways and means to further securing sustainable revenue mobilization policies. The first objective could be pursued by prudently continuing to compete for investment to the extent possible considering the available scope for such under the envisaged Pillar Two approach and on a regionally coordinated basis. Meeting the second objective could occur by furthering the market-based tax base division agenda that has emerged in recent years along with the spread of digital services taxes and in the context of developments towards the construction of the Amount A concept in Pillar One. Such a policy direction could also be pursued if the envisaged Pillars collapse.
Original languageEnglish
Pages (from-to)459-465
Number of pages7
Issue number5
Publication statusPublished - 1 May 2022

Bibliographical note

Funding Information:
2 For some general references and readings in addition to those mentioned and referred to by the commented paper’s author, International Monetary Fund, Revenue Mobilization in Developing Countries, prepared by the Fiscal Affairs Department, approved by Carlo Cottarelli, 8 Mar. 2011, (accessed 20 Nov. 2021), International Monetary Fund, Spillovers in International Corporate Taxation, 2014(071) Policy Papers ( 9 May 2014), available at https://www.imf. org/external/np/pp/eng/2014/050914.pdf (accessed 20 Nov. 2021), Economic and Private Sector Professional Evidence and Applied Knowledge Services, Structured Professional Development, Taxation and Developing Countries, Training Notes (Sep. 2013), (accessed 20 Nov. 2021), and Haileselassie Gebreselassie & Maarten de Wilde, Impact Assessment of Capacity Building Projects in the Ethiopian Justice Sector Institutions; Supported by the Embassy of the Kingdom of the Netherlands in Addis Ababa’, Project Number:28073, Contract Number: 6001337, The Africa-Europe Partnership Institute for Capacity Building and Human Resource Development (AEPICAB), Jul. 2018, (accessed 20 Nov. 2021). For some critique on the merits of recent developments in company taxation from a developing country perspective, and some further references, see Afton Titus, Global Minimum Corporate Tax: A Death Knell for African Country Tax Policies?, to be published, and Fernando Saldivar, Is a Bad Deal Better than no Deal?: A Perspective from Africa on the G7’s Agreement to Restructure International Corporate Taxation, Ethics & International Affairs, Nov. 2021, tional-corporate-taxation/ (accessed 20 Nov. 2021).

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© 2022. Kluwer Law International BV, The Netherland


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