October 2021 / Focus Africa

October 31 2021

Africa in Review by the Numbers (October 2021)

Female business owners on the Jumia platform in Kenya, according to the firm's Africa E-commerce Index 2021. Women represent the same proportion of sellers in Nigeria, another of Africa's leading e-commerce markets. Jumia's CEO cited online retail as being 'inherently female-entrepreneur friendly'. (CapitalFm)
  $300 million
Investment planned by Orange, the French multinational telecommunications company, in Egypt in 2022. This was announced during a meeting between several Egyptian emissaries including Prime Minister Mostafa Madbouly and representatives of a group of the largest French companies held on Monday in Paris. (Egypt Today)
  4,000 tonnes
Annual capacity of Sierra Leone's first cocoa processing plant. The facility, launched by Capitol Foods, one of the country's leading agribusinesses will produce cocoa paste for export, sourcing beans from a network of over 2,800 farmers. (Food Business Africa)
Nigeria's share of the total volume of private equity (PE) deals in West Africa between 2015 and 2020. Africa’s most populous nation also accounted for 54% of the total value of PE funding in the region, according to data from AVCA. Ghana followed at 17% and 26% respectively, and Kenya lead the way in East Africa, having received 61% of the total volume and 58% of the total value of PE deals in the region. (Nairametrics)
  6.5 million bags
Uganda's coffee exports in the year through September, a 30-year peak. Increased uptake was due to growing demand from European buyers, especially Italy’s espresso lovers, amid shipping disruptions in Brazil and Vietnam. (The Citizen)
  $27 billion
Financing sought by South Africa to develop electricity infrastructure to facilitate the shift away from coal. More than 80% of the country's electricity is powered by coal, with Eksom aiming to decommission between 8,000 and 12,000 MW of coal over the next decade. (Reuters)
  85 MW
The total target wattage of the Regional Rusumo Hydroelectric Power Project in Rwanda after implementation of a redesign which could add at least 5 MW to the original 80-MW capacity. The $340 million project will benefit Tanzania, Burundi, and Rwanda, with first power targeted at the end of the year. (New Times)
  $8.9 billion
Amount of financing provided by the European Bank of Reconstruction and Developments (EBRD) to Egypt, according to Rania Al-Mashat, Minister of International Cooperation. In total, the EBRD has financed 143 projects, 75% of which have been from the private sector. Egypt topped the list as the EBRD's largest country of operations in the southern and eastern Mediterranean region in 2020. (Egypt Today)
The number of drone licences that the Kenya Civil Aviation Authority (KCAA) has issued since January. Uptake has been encouraged by changes in legislation enabling drone use from late last year but has been dampened by the high cost of training. A more conducive regulatory framework for use of unmanned drones is expected to support Africa to leapfrog infrastructure challenges. (Business Daily)
  $1.2 billion
The amount expected to be raised by MTN Uganda in the highly anticipated 20% share sale of the telco on the Uganda Securities Exchange. The listing will make MTN Uganda the second publicly traded telecom in the EAC after Safaricom’s IPO on the Nairobi Securities Exchange in 2008. (Daily Monitor)
The reduction in Kenya Power's electricity tariffs due to take effect in December 2021 in a move designed to attract foreign direct investment and spur industrial growth. This development should also prop up power demand and save the struggling utility firm, Kenya Power, from imminent collapse. (The East African)
Wind turbines to be supplied by GE Renewable Energy to Morocco's 200-MW Aftissat onshore wind farm. The new facility is the second windfarm built with GE equipment in the country and will bring the kingdom closer to its target of having 52% of its power from renewable sources by 2030. (Morocco World News)
Global rank of Ethiopian Airlines, which also holds the title of best carrier in Africa for the fourth year in a row, according to the SKYTRAX World Airline Awards 2021. South African Airways and Kenya Airways came in second and third of the continent's airlines. (The East African)
  254k jobs
Kenyan jobs that were shed in the three months to March, despite the economy showing signs of recovery from Covid-19 hardships. While this paints a grim picture of the economy, the World Bank expects Kenya’s economy to grow by 4.5% this year and to climb to above 5% in the subsequent two years (Business Daily)
  100% duty-free
Ghana plans to introduce a full waiver on tariffs for electric vehicle imports. According to Ghana's Minister of Energy, this waiver will reduce greenhouse gas emissions, stimulate demand for the country's excess power capacity and, most importantly, avoid the country becoming a dumping ground for used fossil-fuel cars as the world moves to eco-friendly vehicles. (GhanaWeb)
October 12 2021

African Tax Administration Forum Comments on Global Tax Agreement

The African Tax Administration Forum (ATAF) has issued a statement commenting on the significant progress made towards the global tax agreement (the agreement) that envisages implementing a two-pillar solution towards addressing the tax challenges arising from the digitalization of the economy.

The statement noted that ATAF and African members of the Inclusive Framework (IF) have been heavily involved in the negotiations and the ATAF has been providing technical support to its members to ensure that the new Pillar One and Pillar Two rules address the needs of African countries in ensuring that they are simple, equitable and bridge the gap in the existing tax rules that have been skewed in favour of developed countries.

Pillar One rules

The Pillar One rules incorporate many of ATAF Pillar One proposal recommendations, as follows:

  • the ATAF noted that the Pillar One scope was broadened to include all sectors rather than the narrower scope proposed in the OECD blueprint report released for public consultation in October 2020;
  • the ATAF underlined that the extractives sector has been excluded from the scope of Pillar One;
  • the ATAF welcomed the nexus threshold reduction from EUR 5 million to EUR 1 million and the lower threshold of EUR 250,000 for jurisdictions with GDP lower than EUR 40 billion. The ATAF expressed that this change to the nexus rule shall ensure that no member of the IF will be excluded from receiving its reallocation of profit under the so-called Amount A; and
  • the ATAF had opposed, together with the African Union Commission, the IF's initial recommendation to impose a mandatory dispute resolution mechanism for issues relating to Amount A as it would impose a costly process on many African countries with limited capacity and where there is little risk of double taxation. The ATAF has succeeded in obtaining an agreement that there will be no mandatory dispute resolution mechanism imposed on many African and other developing countries. Instead an elective binding dispute resolution mechanism will be available for issues related to Amount A for developing economies that are eligible for deferral of their BEPS Action 14 peer review (paragraph 7 of the Assessment Methodology chapter of BEPS Action 14 effective dispute resolution mechanisms) and have no or low levels of mutual agreement procedure (MAP) disputes.

The ATAF noted that the agreement does not reallocate part of the routine profit of in-scope MNEs to market jurisdictions. The ATAF stressed that it called for at least 35% of the so-called residual profit to be allocated to market jurisdictions. The agreement only reallocates 25% of the residual profit to market jurisdictions under Amount A. The ATAF acknowledged that the additional allocation of the global profits of the most profitable MNEs to market jurisdictions is a step in the right direction in the reallocation of taxing rights. However, it will not result in the substantial shift in the allocation of taxing rights between residence and source countries that ATAF and African countries have been advocating for to redress the current imbalance in the allocation of taxing rights which favours residence jurisdictions to the detriment of developing countries which are primarily source jurisdictions.

The ATAF expressed that fundamental reallocation of such taxing rights could have been achieved through the ATAF Pillar One proposals. The ATAF added that it will be calling for further work to be done in the global standard setting process to persuade the developed world to agree to a more equitable allocation of taxing rights to provide African and other developing countries with the tax revenue they need to rebuild their economies.

Pillar Two rules

Minimum tax

The Pillar Two rules aim to ensure that all the global profits of MNEs are taxed at least at a minimum effective rate of 15%. However, the ATAF highlighted for such a rule to be effective, the minimum effective rate needed to be at least 20% rather than 15% if it is to stem artificial profit shifting out of Africa as most African countries have a statutory corporate income tax rate of between 25% and 35%.

Rule design

  • The ATAF noted that the agreement gives priority to the Income Inclusion Rule (IIR) and that the Undertaxed Payments Rule (UTPR) will only apply in very limited circumstances. The ATAF has stated that a source-based rule such as the UTPR or the Subject to Tax Rule (STTR, which is a treaty provision rule) should be the primary rule under Pillar Two to assist in redressing the current imbalance in the allocation of taxing rights between residence and source jurisdictions.
  • The ATAF welcomed that the STTR will be a minimum standard that developing countries can require to be included in bilateral tax treaties with IF members applying nominal corporate income tax rates below the STTR minimum rate of 9%. The ATAF has called for the STTR to be broad in scope to cover payments of interest, royalties, all service payments, and capital gains. The IF agreed that the STTR will cover interest, royalties, and a defined set of other payments; the ATAF confirmed that it will continue to monitor what will be included within defined payments as this work progresses in the IF.


The ATAF announced it will work closely with the African Union and African countries on the implementation of the new rules within the timetable of the end of 2023 set out in the IF plan. The ATAF noted that the implementation must be done responsibly and in consideration of the fact that not all countries have a similar capacity to implement the rules.

Regarding the few IF members that have not joined the agreement and the other African countries that are not members of the IF, the ATAF has expressed concern about how the new rules will impact upon those countries and that political pressure should not be brought on such countries to apply these rules or to join the IF.

The work that the ATAF's membership and the African Union have done in the negotiations on the two-pillar solution has been ground breaking and pioneering work for Africa, and it has meant that for the first time, Africa has been able to have its tax policy objectives better reflected in the global tax rules.

The ATAF statement was released on 8 October 2021.

October 27 2021

Rwanda Joins Regional Initiatives for Tax Transparency

According to a press release of 25 October 2021 published by the OECD, Rwanda has joined the Yaoundé Declaration, affirming the African initiatives for tax transparency and exchange of information for tax purposes and for tackling illicit financial flows (IFFs) through international tax cooperation.

The Yaoundé Declaration was originally signed on 15 November 2017 in Yaoundé (Cameroon), by four countries, namely Benin, Cameroon, Liberia and Uganda (see text in English here), during the tenth Plenary meeting of the Global Forum on Transparency and Exchange of Information for Tax Purposes (the Global Forum).

Rwanda is now the 31st African country, with the African Union Commission, to adhere to the Declaration. The other countries are Benin, Burkina Faso, Cameroon, Cape Verde, Chad, Comoros, Congo, Djibouti, Egypt, eSwatini, Gabon, Ghana, Guinea-Bissau, Ivory Coast, Kenya, Lesotho, Liberia, Madagascar, Mali, Mauritius, Mauritania, Morocco, Niger, Nigeria, South Africa, Senegal, Seychelles, Togo, Tunisia and Uganda.

More info can be found on the OECD website.