Africa | Taxation Services | 26 April 2017

Africa Tax Alert

Further tax developments in Africa

26 April 2017
Algeria / Angola / Cameroon / Gambia / Ghana / Guinea / Kenya /
Liberia / Libya / Malawi / Mauritius / Morocco / Nigeria / Rwanda /
Swaziland / Tunisia / Uganda / Zambia
*References

Algeria

Foreign Account Tax Compliance Act (FATCA) agreement

The US Internal Revenue Service (IRS) released the official text of the competent
authority agreement (CAA) that the United States has signed with Algeria in
accordance with the Algeria - United States FATCA Model 1B Agreement (2015) for
implementation of FATCA.
More

Angola

Investment Protection Agreement (IPA) with United Arab Emirates

Angola and the United Arab Emirates signed an IPA in Abu Dhabi on 5 April 2017.

Cameroon

Investment Protection Agreement (IPA) with Korea (Rep.)

An IPA between Cameroon and Korea (Rep.) was signed and approved by the
Senate of Cameroon on 6 April 2017.

Tax treaty between Cameroon and South Africa

The tax treaty between Cameroon and South Africa was approved by the Senate of
Cameroon on 6 April 2017.
Gambia

Tax treaty between Gambia and Mauritius

According to an update published by the tax authorities in Mauritius, negotiations
for a tax treaty between Gambia and Mauritius have been concluded and the treaty
is now awaiting signature.

Ghana

Tax amendment bills

The Value Added Tax (Amendment) Bill 2017 and the Energy Sector Levies
(Amendment) Bill 2017 were presented by the Minister of Finance for consideration.

Tax holiday for start-up businesses**

On 8 April 2017, the Minister for Business Development announced a proposal to
grant 1-year tax holidays to start-up businesses in order to create an enabling
environment for small and medium-sized enterprises.
More

Practice Notes
A number of practice notes have recently become available, dealing with various
topics including the taxation of employment income, realisation of assets on a
change of ownership (including sale, merger and amalgamation), deductibility of
donations, capital allowances, separation of the banking business of a company,
and carry forward of losses.
More / More / More / More

Tax treaty between Ghana and Singapore

The Ghana - Singapore Income Tax Treaty (2017) was signed in Ghana on 31
March 2017.

Exchange of information agreement between Ghana and Guernsey

Ghana and Guernsey have initialled an exchange of information agreement relating
to tax matters.

Tax treaty between Czech Republic and Ghana

The Czech Republic - Ghana Income Tax Treaty (2017) was signed in Accra on 11
April 2017.

Guinea

Investment Protection Agreement (IPA) between Canada and Guinea

The IPA between Canada and Guinea, signed on 27 May 2015, entered into force on
27 March 2017.
More

Kenya

Tax treaty between Kenya and Korea (Rep.)

The Kenya - Korea (Rep.) Income Tax Treaty (2014) entered into force on 3 April
2017. The treaty applies from 1 January 2018.

Finance Bill 2017

The Finance Bill 2017 was published on 3 April 2017 following the presentation of
the Budget to the National Assembly on 30 March 2017.
More
Foreign Income and Assets Tax Amnesty Guidelines 2017
The Kenyan Revenue Authority has issued the Foreign Income and Assets Tax
Amnesty Guidelines 2017. The Guidelines, issued under section 37B of the Tax
Procedures Act 2015, became effective from 1 January 2017.
More

Liberia

Excise duty rates revised

The Liberia Revenue Authority published a Government Notice on 27 March 2017,
notifying the general public about the revision of the excise duty rates of certain
goods and services. The revised rates became effective on 22 December 2016.
More

Real property tax rate increased*

The Liberia Revenue Authority published a Government Notice on 27 March 2017,
announcing the increase of the property tax rates of certain categories of land. The
revised rates will become effective from 1 April 2017.
More

Revised customs procedures announced*

The Liberia Revenue Authority published a Government Notice announcing the
changes to the customs procedures at land borders, seaports and airports.
More

Malawi

Tax treaty between Malawi and Mauritius

According to an update published by the tax authorities of Mauritius, negotiations
for a tax treaty between Malawi and Mauritius have been concluded and the treaty
is now awaiting signature.

Tax treaty between Malawi and Zambia

Malawi and Zambia signed a tax treaty on 6 April 2017. The tax treaty was signed
in Lusaka during the 15th session of the Zambia/Malawi Joint Permanent
Commission (JPC).

Mauritius

Tax treaty between Gambia and Mauritius

According to an update published by the tax authorities of Mauritius, negotiations
for a tax treaty between Gambia and Mauritius have been concluded and the treaty
is now awaiting signature.

Tax treaty between Gibraltar and Mauritius

According to an update published by the tax authorities of Mauritius, negotiations
for a tax treaty between Gibraltar and Mauritius have been concluded and the treaty
is now awaiting signature.

Tax treaty between Malawi and Mauritius

According to an update published by the tax authorities of Mauritius, negotiations
for a tax treaty between Malawi and Mauritius have been concluded and the treaty
is now awaiting signature.
Exchange of information agreement between Korea (Rep.) and Mauritius*
The Korea (Rep.) - Mauritius Exchange of Information Agreement (2016) entered
into force on 13 April 2017. The agreement generally applies from 13 April 2017 for
criminal tax matters and from 1 January 2018 for Korea (Rep.) and from 1 July
2018 for Mauritius for all other tax matters.

Morocco

Tax treaty between Morocco and Rwanda

The Council of Ministers of Rwanda approved the Morocco - Rwanda Income Tax
Treaty (2016) on 5 April 2017.

Revaluation coefficients for income tax on disposals of immovable

property*
The Ministry of Finance fixed the revaluation coefficients for income tax on the
disposals of immovable property (article 65-II of the General Tax Code) by
Ministerial Decree No. 526-17 of 13 March 2017 published in Official Gazette No.
6558 of 6 April 2017.

Maximum deductible interest payable to shareholders for 2017

Ministerial Decree No. 525-17 of 13 March 2017, was published in Official Gazette
No. 6558 of 6 April 2017, setting the maximum rate of deductible interest payable
to shareholders at 2.21% for the year 2017 (the rate had been 2.53% in 2016).

Nigeria

Revised transfer pricing forms*

The Federal Inland Revenue Service has issued revised versions of the Transfer
Pricing (TP) Declaration Form and the TP Disclosure Form, including the TP
Declaration Form Guidelines and TP Disclosure Form Guidelines for completing the
TP Declaration Form and TP Disclosure Form were also released.
All connected taxable persons are required to file annual TP returns using the
revised forms as effective 1 January 2017.
More / More /More /More

Deloitte comments on the Draft National Petroleum Fiscal Policy

This commentary highlights the implications of the new policy for stakeholders in
view of attempts to create a sustainable oil and gas industry for the country.
More

Rwanda

Tax treaty between Morocco and Rwanda

The Council of Ministers of Rwanda approved the Morocco - Rwanda Income Tax
Treaty (2016) on 5 April 2017.

Swaziland

Requirements for bonded warehouses

The Swaziland Revenue Authority (SRA) published the requirements for obtaining a
licence to operate, as well as the security requirements for, bonded warehouses on
11 April 2017. The establishment of duty warehouses is provided for under section
17 of the Customs and Excise Act 1971.
More
Tunisia

Social security agreement between Bulgaria and Tunisia

The Bulgaria - Tunisia Social Security Agreement (2015) will enter into force on 1
May 2017. The agreement generally applies from 1 May 2017.

Uganda

VAT (Amendment) Bill 2017*

The Minister of Finance, Planning and Economic Development presented the Value
Added Tax (VAT) (Amendment) Bill 2017 to parliament for consideration on 4 April
2017. The Bill proposes to amend the VAT Act by exempting the following supplies
of goods and services from VAT, aimed at promoting productivity in the agricultural
sector:
– irrigation equipment;
– animal feeds; and
– crop extension services.

National Budget Framework Paper 2017/18

The Ministry of Finance, Planning and Economic Development published the
approved National Budget Framework Paper 2017/18 (the NBFP) on 31 March 2017.
The NBFP proposes changes in the Budget for 2017/18 to the following taxes:
- Direct taxation
- Indirect taxation
- Tax Administration
- Business and investment.
More

Zambia

Tax treaty between Malawi and Zambia

Malawi and Zambia signed a tax treaty on 6 April 2017. The tax treaty was signed
in Lusaka during the 15th session of the Zambia/Malawi Joint Permanent
Commission (JPC).

*References:
Cameroon: Report by Pierre Burg, IBFD correspondent.
Ghana: Report from Eric Kwaku Kegya, IBFD tax and business development Accra**
Ghana: Report from Eric Kwaku Kegya, UHY Voscon, Accra**
Liberia: Report from Obiageli Chiedu, ACTI (Nig), IBFD Research Associate
Mauritius: Report from IBFD Tax Treaties Unit
Mauritius: Report from Pamela Chitulangoma, Principal Budget Analyst, Budget Office, Ministry of Finance
Morocco: Report from Yassir Kamal Kaikani, IBFD International tax consultant
Nigeria: Report from Obiageli Chiedu, ACTI (Nig.), IBFD Research Associate.
Rwanda: Report from Obiageli Chiedu, ACTI (Nig.), IBFD Research Associate
Uganda: Report from Obiageli Chiedu, ACTI (Nig) IBFD Research Associate
Zambia: Report from Pamela Chitulangoma, Principal Budget Analyst, Budget Office, Ministry of Finance
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