NL-Africa Tax Newsletter – March 2024

Dear business relation,

This month’s NL-Africa Tax Desk newsletter includes an update on the Dutch tax treaty negotiations with several African countries. Next to that, it includes updates on the 2024-2025 budgets of Malawi and Namibia, and South African draft legislation to implement Pillar Two.

Furthermore, you can still register for the 2024 KPMG Africa Tax Summit on 16-17 April in Johannesburg, South Africa. Themed Africa Rising, this summit is designed for executives leading tax and finance functions with oversight for African operations. Summit delegates can expect to be inspired by regional speakers, equipped to tackle today’s technical challenges, enlightened by the experiences of their peers, and insights from tax administrators, and enriched by networking and relationship-building opportunities. You can register here.

If you would like to know more about the matters addressed in this newsletter or have any feedback, you are welcome to contact Sebastiaan Paling (Head of the NL-Africa Tax Desk). Please visit our website for more information on the NL-Africa Tax Newsletter and the services we offer or to download our factsheet.

Best regards,
NL-Africa Tax Desk team
Meijburg & Co

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Africa 

• BEPS 2.0 (Pillar Two) global updates
• Taxation of the digitalized economy
• Transfer pricing documentation summaries by jurisdiction
• West African Tax Administration Forum (WATAF) comments on OECD/G20 Inclusive Framework’s report on Pillar One - Amount B

Angola

•  Revisions to VAT law, including taxation of e-commerce transactions

Kenya

• New platform for non-VAT registered taxpayers to electronically generate and send invoices

Malawi

• Malawi Budget 2024/25: Malawi announces tax reforms in corporate income tax and personal income tax

Morocco

• VAT on cross-border provision of digital services

Mozambique

• Mandatory registration of ultimate beneficiaries
• New visa and resident permit fees

Namibia

• Tax measures in budget 2024-2025

Netherlands

• Netherlands updates Common Reporting Standard (CRS) list by removing Trinidad and Tobago, and adding Kenya, Liberia, Morocco and Rwanda (in Dutch only)
• Update on tax treaty negotiations: ratification of tax treaty with Malawi withdrawn, Kenya and Rwanda removed from 2024 tax treaty negotiations planning and Benin added to 2024 tax treaty negotiations planning (in Dutch only)

Nigeria

• Executive orders relating to petroleum sector include new tax incentives
• Federal government nixes implementation of expatriate employment levy for now
• Introduction of self-registration module on electronic platform
• NMDPRA’s right to impose and collect certain levies upheld (Federal High Court decision)

Rwanda

• Rwanda gazettes incentives for voluntary disclosure of tax liabilities
• Rwanda implements reward for final consumers who request electronic billing machine VAT invoices

South Africa

• Draft legislation implementing Pillar Two global minimum tax
• South Africa issues guidance on Solar Energy Tax Credit
• South African Tax Court: CUP Transfer Pricing method is sufficient to determine reasonable arm's length in royalties

Zambia

• VAT on cross-border provision of digital services