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
https://doi.org/10.47348/AMTJ/V6/i1a1

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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
https://doi.org/10.47348/AMTJ/V6/i1a1

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% to 27%, 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%. 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. 24–40
https://doi.org/10.47348/AMTJ/V6/i1a2

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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
https://doi.org/10.47348/AMTJ/V6/i1a2

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.

The Impact of Tax Expenditure (TE) on Sustainable Development Goals (SDGs) in Nigeria: An Opportunity Cost Approach — Evidence from Newey-West Regression

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

The Impact of Tax Expenditure (TE) on Sustainable Development Goals (SDGs) in Nigeria: An Opportunity Cost Approach — Evidence from Newey-West Regression

Authors: Alhasan Usman, Bilkisu Inuwa Jibril, Sha’awa Mohammed & Nafisa Lawan

ISSN: 2709-8575
Affiliations: PhD; Tax Operation Group Federal Capital Territory Internal Revenue Service (FCT-IRS); Large Taxpayers Group, Nigeria Revenue Service (NRS); PhD; Department of Research and Statistics, Nigeria Revenue Service (NRS); Tax Operation Group Federal Capital Territory Internal Revenue Service (FCT-IRS)
Source: African Multidisciplinary Tax Journal, Volume 6, Issue 1 (2026), p. 41–72
https://doi.org/10.47348/AMTJ/V6/i1a3

Abstract

Tax expenditure (TE) remains an area of contention in fiscal policy debate: it is seen as a legitimate instrument for investment promotion and economic stimulus that can expand the tax base over time; on the other hand, critics argue that the revenue forgone by TE means that resources are diverted away from financing the Sustainable Development Goals (SDGs) without commensurate developmental benefits. This study empirically investigates the nexus between TE and the attainment of the SDGs in Nigeria, using quarterly time series data from January 2019 to December 2025. Given confirmed heteroskedasticity and serial correlation, the Newey-West heteroskedasticity and autocorrelation consistent (HAC) estimator is used as the primary basis for statistical inference, with Ordinary Least Squares (OLS) regression reported alongside as a robustness and coefficient-stability check. The study adopts two regression specifications: the baseline regression model to study the unmoderated effects of GDP, tax revenue, TE, debt servicing and foreign aid on SDG outcomes, and a moderated regression model with institutional quality (IQ) as a moderating variable. Model stability is confirmed by the Ramsey RESET test. The results indicate that TE negatively affects the progress of the SDGs in a statistically significant manner. Likewise, debt servicing (DS) constrains development outcomes. The results reveal positive relationships between GDP, tax revenue, foreign aid and SDG performance, but the introduction of institutional quality as a moderator significantly diminishes these effects by 91.2%, 82.0% and 43.9% respectively, making the effects of tax revenue and foreign aid statistically insignificant. Weak institutional quality worsened the negative impacts of TE and DS by 25.18% and 44.75%, respectively. These results validate the opportunity cost of TE policy in Nigeria. Lost revenue is a binding constraint on SDG financing and is compounded by severe institutional deficiencies that reduce the developmental returns to available fiscal resources. The study advocates for a holistic TE policy reform, underpinned by rigorous cost–benefit and opportunity cost analyses and institutional capacity-building to enhance the developmental returns of fiscal policy and economic growth.

Taxing Informality in Malawi: A Comparative Assessment of Policy Instruments and the Role of Digitalisation

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

Taxing Informality in Malawi: A Comparative Assessment of Policy Instruments and the Role of Digitalisation

Author: Waziona Ligomeka

ISSN: 2709-8575
Affiliations: Director in the Revenue Policy Division of the Ministry of Finance, Economic Planning and Decentralisation, Malawi
Source: African Multidisciplinary Tax Journal, Volume 6, Issue 1 (2026), p. 73–94
https://doi.org/10.47348/AMTJ/V6/i1a4

Abstract

Malawi faces sustained fiscal pressures stemming from reduced external assistance, recurring macroeconomic shocks and rising public debt. Strengthening domestic revenue mobilisation has therefore become a central policy priority. Although the informal economy accounts for a substantial share of employment and economic activity, it remains difficult to tax because many enterprises operate with low and irregular incomes, limited accounting records, cash-based transactions and weak visibility to tax authorities. This study comparatively examines five instruments used to tax and formalise informal economic activity in Malawi: advance income tax (AIT) on imports, the block management system (BMS), withholding tax (WHT), tax clearance certificates (TCCs) and presumptive tax. Using a qualitative comparative policy-analysis design, the study draws on legislation, Malawi Revenue Authority (MRA) publications, policy reports and academic literature. The instruments are assessed against four criteria: revenue mobilisation, administrative feasibility, compliance and formalisation outcomes, and long-term sustainability. The analysis suggests that indirect, transaction-based instruments, particularly WHT and AIT, are comparatively more effective than direct field-based approaches because they operate through observable transactions and third-party intermediaries. TCCs also provide a strong incentive for compliance by linking tax status to access to public procurement, importation, licensing and other regulated commercial opportunities. By contrast, BMS and presumptive tax have modest short-term revenue potential but remain important as mechanisms for taxpayer-discovery and simplified entry points into the tax system. Digitalisation can strengthen all five instruments by improving taxpayer identification, transaction traceability, data integration and risk-based enforcement. The study concludes that informal-sector taxation should be understood formalisation, rather than as an immediate mechanism for extracting substantial revenue from micro-enterprises.

Sustainability Management and Corporate Tax Aggressiveness Among Energy-Intensive Firms in Nigeria

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

Sustainability Management and Corporate Tax Aggressiveness Among Energy-Intensive Firms in Nigeria

Authors: Akeem Adetunji Siyanbola; Mukail Oyesegun Oyekanmi; Chukwudi Segun Afolabi; Tajudeen Adewale Odetayo; Moses Babatunde Olanisebe and Joshua Kehinde Ogunleye

ISSN: 2709-8575
Affiliations: University of Ilesa, Nigeria; University of Ilesa, Nigeria; University of Ilesa, Nigeria; University of Ilesa, Nigeria; Obafemi Awolowo University, Ile Ife, Nigeria; Osun State College of Education, Ila Orangun, Nigeria
Source: African Multidisciplinary Tax Journal, Volume 6, Issue 1 (2026), p. 95–121
https://doi.org/10.47348/AMTJ/V6/i1a5

Abstract

This study examines the relationship between sustainability management and corporate tax aggressiveness, proxied by discretionary book-tax differences (DD_BTD), among 56 Nigerian energy-intensive firms between 2018 and 2024. Using 392 firm-year observations and panel regression analysis, the research investigates how resource productivity index (RPI), deferred environmental liabilities (DEL), human capital investment intensity (HCI) and social investment ratio (SIR) influence tax planning. Descriptive statistics reveal mild average tax aggressiveness (mean DD_BTD = 4.37%) alongside substantial heterogeneity in sustainability investments. Regression results show that environmental proxies (RPI and DEL), grounded in the natural resource-based view, are not significantly associated with tax aggressiveness, suggesting limited disciplinary effects of eco-efficiency and liability recognition. In contrast, both HCI and SIR exhibit strong, statistically significant positive relationships with DD_BTD. Drawing on legitimacy theory, this finding suggests that firms employ social and internal investments as ‘moral capital’ to shield aggressive tax practices from scrutiny. Stakeholder theory further explains that such spending aligns with stakeholder expectations, even while masking opportunistic fiscal behaviour. The political cost hypothesis reinforces this by showing how legitimacy-building investments reduce political costs, thereby enabling tax aggressiveness. The study concludes that, in Nigeria, social sustainability maturity paradoxically facilitates rather than constrains aggressive tax planning.

Tax Transition in ECOWAS: Leveraging the AfCFTA as a Catalyst for Domestic Resource Mobilization

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

Tax Transition in ECOWAS: Leveraging the AfCFTA as a Catalyst for Domestic Resource Mobilization

Authors: Youssifou Aguorigoh and Traoré Firdaws Galadima

ISSN: 2709-8575
Affiliations: Lund University (School of Economics and Management); Université de Lomé (Faculté des Sciences Économiques et de Gestion); Lund University (School of Economics and Management); Université de Lomé (Faculté des Sciences Économiques et de Gestion)
Source: African Multidisciplinary Tax Journal, Volume 6, Issue 1 (2026), pp. 122–142
https://doi.org/10.47348/AMTJ/V6/i1a6

Abstract

This study examines whether the African Continental Free Trade Area (AfCFTA) can strengthen domestic revenue mobilisation in ECOWAS countries through increased intra-African trade. AfCFTA-induced trade potential is first estimated using a structural gravity model with high-dimensional fixed effects and Poisson pseudo-maximum likelihood over the period 2000–2022. The estimated trade potential is then incorporated into a dynamic system GMM framework to assess its impact on domestic tax revenues, with robustness checks based on alternative estimators and the tax to GDP ratio. The results indicate that the AfCFTA significantly increases trade potential, revealing an untapped intra-African trade potential of about 11%. The findings further show that AfCFTA-induced trade potential positively affects domestic tax revenues, supporting the fiscal transition hypothesis. The study contributes by integrating structural gravity estimates with dynamic panel analysis and highlights the need for complementary domestic tax reforms to maximise the fiscal benefits of regional integration.