Legal and Economic Impacts of Globe Pillar Two on South African Oil and Gas Taxation

Legal and Economic Impacts of Globe Pillar Two on South African Oil and Gas Taxation

by | Aug 6, 2026 | AMTJ, AMTJ 2026 I1

Legal and Economic Impacts of Globe Pillar Two on South African Oil and Gas Taxation

Authors: Alison Futter and Tracy Johnson

ISSN: 2709-8575
Affiliations: PhD; Department of Finance and Tax; Tax Unit for Fiscal Research, University of Cape Town, South Africa; MCom Department of Finance and Tax; Tax Unit for Fiscal Research, University of Cape Town, South Africa
Source: African Multidisciplinary Tax Journal, Volume 6, Issue 1 (2026), p. 1–23

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Alison Futter and Tracy Johnson
Legal and Economic Impacts of Globe Pillar Two on South African Oil and Gas Taxation
African Multidisciplinary Tax Journal Volume 6, Issue 1 (2026) p. 1–23

Abstract

This article examines how the OECD/G20 Global Anti-Base Erosion (GloBE) Pillar Two rules affect the legal design and project economics of South Africa’s upstream oil and gas tax regime. It addresses a gap in the literature by combining doctrinal analysis of the Global Minimum Tax Act 46 of 2024 with an adaptation of the IMF’s Fiscal Analysis of Resource Industries model for a representative project. Under the modelled assumptions, the Qualifying Domestic Minimum Topup Tax reduces the investor’s internal rate of return from 29 per cent to 27 per cent, and its net present value (NPV) from US$4.792 billion to US$4.423 billion, while increasing the NPV of government fiscal receipts excluding state participation by 13.7 per cent. A scenario applying the 2026 Substance-based Tax Incentive Safe Harbour partly restores investor returns. The article concludes that Pillar Two partially neutralises the Tenth Schedule incentives and proposes a policy response for incentive design, legislative oversight and fiscal-stability negotiations.

Legal and Economic Impacts of Globe Pillar Two on South African Oil and Gas Taxation

Impact Assessment of the Taxation of the Informal Sector on Tax Revenue in Togo

by | Aug 6, 2026 | AMTJ, AMTJ 2026 I1

Impact Assessment of the Taxation of the Informal Sector on Tax Revenue in Togo

Author: AGBE Yaovi Fagda Tchota

ISSN: 2709-8575
Affiliations: Docteur en Sciences Economiques, Spécialiste certifié en Evaluation d’impact par le CIFOIT, Chargé d’études à l’Office Togolais des Recettes (OTR), Membre du Centre de Recherche en Economie Appliquée et Management des Organisations (CREAMO) de la Faculté des Sciences Economiques et de Gestion de l’Université de Lomé-Togo
Source: African Multidisciplinary Tax Journal, Volume 6, Issue 1 (2026), p. 1–26

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AGBE Yaovi Fagda Tchota
Impact Assessment of the Taxation of the Informal Sector on Tax Revenue in Togo
African Multidisciplinary Tax Journal Volume 6, Issue 1 (2026) p. 24–40

Abstract

This paper assesses the impact of taxing the informal sector on tax revenue in Togo using propensity score matching. An analysis of the determinants of firms’ registration decisions using a probit model shows that operating in the secondary and tertiary sectors negatively affects the probability of firm registration, with a more pronounced effect in the secondary sector. Firms operating in rented premises and having a lease agreement, as well as those headed by wealthy and educated individuals who hold a Tax Identification Number, are more likely to register. Regarding the impact assessment, the results indicate that taxing the informal sector contributes, on average, to an increase in tax revenue per firm, with the estimated increase ranging from 149,245 FCFA to 149,437 FCFA.

Taxation in the Digital Economy and the Challenges of the Mozambican Tax System

by | Aug 6, 2026 | AMTJ, AMTJ 2026 I1

Taxation in the Digital Economy and the Challenges of the Mozambican Tax System

Authors: Milton Acácio Langa, Gilberto Leopoldo de Mata Solomone, Jerónimo Paulo Uamba & Manuel Augusto Franque Bento

ISSN: 2709-8575
Affiliations: N/A
Source: African Multidisciplinary Tax Journal, Volume 6, Issue 1 (2026)

Abstract

This study analyses Digital Economy Taxation, identifying the main challenges faced by the Mozambican Tax System between 2023 and 2025, examining the relevance of nexus (connecting-factor) criteria for taxing the digital economy, and proposing improvements to the tax system to promote tax fairness and prevent competitive distortions. A mixed-methods approach was used: a qualitative, descriptive and exploratory strand, based on semi-structured interviews with two officials from the Mozambican Tax Authority, analysed using content analysis; and a quantitative strand, based on an online questionnaire administered to 163 individuals, analysed using statistical techniques (descriptive statistics, chi-square test, Student’s t-test, ANOVA, principal component analysis, cluster analysis and discriminant analysis). The results reveal that taxing capacity is limited by gaps in legislation, the absence of connecting-factor criteria, insufficient technological integration, and difficulty tracing cross-border digital transactions, despite the growth of the digital economy in Mozambique. The study concludes that tax-system reforms are needed to address digital-economy taxation, together with strengthened technology at the Tax Authority and the implementation of international cooperation strategies. The study contributes to the literature on digital-economy taxation in African contexts and offers practical implications for tax policy formulation in Mozambique.

Corporate Taxation in Senegal: Reform and Tax Avoidance

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Corporate Taxation in Senegal: Reform and Tax Avoidance

Authors: Luisito Bertinelli, Arnaud Bourgain, Seydi Ababacar Dieng & Jean-Paul Diagne

ISSN: 2709-8575
Affiliations: N/A
Source: African Multidisciplinary Tax Journal, Volume 6, Issue 1 (2026)

Abstract

This paper examines corporate income taxation in Senegal using firm-level data from the Agence Nationale de la Statistique et de la Démographie (ANSD), covering nearly the entire formal private sector over the period 2008–2019. This study uses firms’ effective tax rates (ETRs) to assess the actual corporate tax burden and identify the main determinants of tax avoidance. Particular attention is paid to the effects of the 2013 tax reform. Empirical results show that effective tax rates increased overall after the 2013 reform but declined for large firms. These findings are robust across alternative specifications and measures of effective taxation. The results support a review of tax incentives and exemptions, particularly those benefiting large and export-oriented firms.

Governance and Tax Revenue Mobilisation in Benin

by | Aug 6, 2026 | AMTJ, AMTJ 2026 I1

Governance and Tax Revenue Mobilisation in Benin

Authors: Hounmenou Mahoutondji Jonas & Honlonkou Albert N’lédji

ISSN: 2709-8575
Affiliations: N/A
Source: African Multidisciplinary Tax Journal, Volume 6, Issue 1 (2026)

Abstract

Revenue mobilisation has become one of the major challenges facing African countries in general, and Benin in particular, in financing their various development programmes. This paper aims to analyse the effect of governance on tax revenue in Benin. Theoretically, good governance is assumed to improve the level of revenue mobilisation. This hypothesis is tested empirically using secondary data from the World Bank covering the period 1970 to 2023. Results obtained from a dynamic approach based on an error-correction model show that economic and political governance have a positive impact on tax revenue mobilisation in Benin. Institutional governance, however, does not currently appear to affect revenue mobilisation, which may be explained by the persistent weakness of this indicator over the entire period analysed.

Potential of Tax Resources in WAEMU Member States: Estimating the VAT Gap and Its Determinants

by | Aug 6, 2026 | AMTJ, AMTJ 2026 I1

Potential of Tax Resources in WAEMU Member States: Estimating the VAT Gap and Its Determinants

Author: Isaac Amedanou

ISSN: 2709-8575
Affiliations: N/A
Source: African Multidisciplinary Tax Journal, Volume 6, Issue 1 (2026)

Abstract

This paper focuses on estimates of the VAT gap in WAEMU Member States using the “top-down approach” and conducts econometric analysis to help understand the nature and causes of the VAT gap, and to identify country-specific characteristics that appear related to different levels of the VAT gap. The VAT gap is the difference between the theoretical VAT liability and the VAT actually collected, expressed in relative terms as a share of theoretical VAT liability. Across all Member States, the overall VAT gap stood at 68% in 2006 and declined, on average, by approximately 7 percentage points to 61% by 2015. At the country level, the estimated VAT gap ranges from 37.7% in Togo to 64.9% in Côte d’Ivoire. Econometric analysis, using Panel Corrected Standard Errors, robust OLS regression, and IV methods, was conducted to identify the factors that explain the different levels of the VAT gap. Two variables were found to have the strongest relationship with the level of the VAT gap: the VAT gap share increases with the final consumption ratio-to-GDP of households and non-profit institutions serving households, and, when the VAT burden (the ratio of theoretical VAT liability to GDP) is included as a candidate explanatory variable, a significantly positive association with the VAT gap emerges. After accounting for the risk that this correlation could be biased by measurement errors through IV regression, the relationship becomes negative and significant.