NL-Africa Tax Newsletter – November 2025

Dear business relation,

This month’s NL-Africa Tax Desk newsletter includes, amongst others, updates on Pillar 2 in Kenya & Mauritius, capital gains taxation in Nigeria and transfer pricing documentation requirements in Morrocco.   

If you would like to know more about the other 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 Desk and the services we offer or to download our factsheet.

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

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Africa 

• KPMG BEPS 2.0 (Pillar Two) tracker
• Taxation of the digitalized economy
• Transfer pricing documentation summaries by jurisdiction
• ATAF’s suggested approach to drafting significant economic presence legislation in Africa 

Botswana

• Amendments to VAT law enacted

Cameroon

• Ministry of Finance publishes a circular on the practical application of MAPs  

Ethiopia

• Proposal for new tax incentives for exports, startups and green energy projects 

Ghana

• Mandatory use of fiscal electronic devices beginning early 2026
• Tax measures in 2026 budget

Kenya 

• Draft regulations proposing new framework for advance pricing agreements (APAs)
• High Court rules that digital platform operators with transactional control are liable for VAT
• KRA introduces automated payment plan for settlement of tax liabilities
• KRA publishes draft income tax regulation on Pillar Two minimum top-up tax for 2025
• New standards levy on manufacturers 

Liberia

• 2026 draft budget with several measures aimed at boosting tax revenue

Mauritania

• Tax provisions in Supplementary Finance Law for 2025

Mauritius

• MRA publishes compliance criteria for the Fair Share Contribution
• QDMTT notification platform open, deadline for notifications extended to November 30

Morocco

• Draft decree on transfer pricing documentation requirements 

Mozambique

• The new challenges in the application of Double Tax Agreements 

Namibia

• 2025/2026 Mid-Year Budget summary
• Namibia Revenue Agency extends the deadline to submit income tax returns relating to the limitation of carry-forward losses 

Nigeria

• Constitutional amendment proposed to address multiplicity of taxes
• Transition to new economic development tax incentive scheme
• What you need to know about the new capital gains tax rules and capital market investment in shares

South Africa

• Compliance requirements for income transfers by residents to nonresidents
• Finance Minister introduces Taxation Laws Amendment Bill
• Proposed amendments to application of “conduit principle” in relation to trust distributions
• SARS publishes an updated guide on the supply of electronic services by foreign suppliers and foreign intermediaries
• Tax incentive for energy-efficiency savings extended through 2030
• Tax implications of introduction of ZARONIA as key reference interest rate