International tax cooperation and governance is entering a new era in which rival frameworks are contesting the boundaries of fiscal sovereignty and reshaping the path of development policy. The OECD’s Pillars One and Two seek to curb base erosion and profit shifting but risk imposing uniform standards influenced predominantly by developed economies which potentially constrains developing countries’ policy leverage. In contrast, the emerging United Nation (UN) Tax Convention advanced by Nigeria on behalf of the African Group offers an inclusive and source-based approach aimed at greater equity and fiscal justice. This article examines how African states navigate these competing regimes by exploring whether they generate synergies or intensify fragmentation in African tax governance. It uses case studies of Kenya, Nigeria, Rwanda, and South Africa to analyse national strategies from Nigeria’s leadership in UN ITC processes to South Africa’s calibrated engagement with OECD frameworks and considers their implications for collective African interests. The study situates these dynamics within a shifting multipolar order and emphasizes the need for African unity in articulating a coherent position. It is argued that an African Union (AU)-led governance framework is essential for harmonizing obligations, safeguarding fiscal sovereignty, and advancing a distinctive African agenda for global tax reform that balances compliance, equity, and development.
Intertax