Tax Treaties in Sub-Saharan Africa - A critical review

This publication critically examines tax treaties in sub-Saharan Africa, focusing on the historical development of tax treaty networks and the key concerns in their content. Using Uganda and Zambia as case studies, it explores the motivations behind the review and renegotiation of tax treaties in these countries. The report highlights vulnerabilities in areas such as withholding taxes, permanent establishment, capital gains, treaty shopping/anti-avoidance, and administrative cooperation. It also discusses recent initiatives by individual countries, regional organizations, and international bodies. The publication concludes with recommendations for African countries to review existing tax treaties, formulate ambitious national models, renegotiate high-impact treaties, and strengthen transparency and parliamentary approval processes.