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Debate: International Company Tax Developments And Some Reflections On Ways Forward For The African Continent

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Debate: International Company Tax Developments And Some Reflections On Ways Forward For The African Continent


Intertax
Volume 50, Issue 5 (2022) pp. 459 – 465

https://doi.org/10.54648/taxi2022040



Abstract

The article comments on the contribution in this edition entitled ‘Unilateral Digital Services Tax in Africa; Legislative Challenges and Opportunities’. The current paper also serves as an independent reflection on contemporary developments in company taxation and potential ways forward in this regard for the African continent. With a view to submitting suggestions that could cater to the needs and revenue mobilization interests of African countries and – building on the observations of the commented paper’s author – the current paper proposes some suggestions for potential tax policy approaches for Africa. These are based on securing two objectives: (1) maintain and/or attract investment while (2) devising ways and means to further securing sustainable revenue mobilization policies. The first objective could be pursued by prudently continuing to compete for investment to the extent possible considering the available scope for such under the envisaged Pillar Two approach and on a regionally coordinated basis. Meeting the second objective could occur by furthering the market-based tax base division agenda that has emerged in recent years along with the spread of digital services taxes and in the context of developments towards the construction of the Amount A concept in Pillar One. Such a policy direction could also be pursued if the envisaged Pillars collapse.


Keywords

Corporate Income Tax, base erosion and profit shifting (BEPS), Pillar One, Pillar Two, tax competition, special tax zones, tax incentive regimes, developing countries, developing world, Africa, capacity building, human resource development, fairness.


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