Showing 1-12 of 110 publications
June 2020

A Simplified Method for Taxing Multinationals for Developing Countries: Building on the ‘Amount B’ Proposal to Repair the Transactional Net Margin Method

Michael C. Durst

This paper considers whether the ‘Amount B’ proposal currently being negotiated in the Inclusive Framework, for the attribution of fixed remuneration for the ‘routine’ distribution and marketing activities of MNE affiliates, may offer a useful template for the re-working of the widely used ‘transactional net margin’ transfer pricing method (TNMM). The TNMM has for years…

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June 2020

The Taxation of the Digitalised Economy: An African Study

Mustapha Ndajiwo

The advent of digitalised business models has considerable potential to improve trade in Africa, however, it has greatly exacerbated the two central challenges of international tax. The first challenge is the definition of taxable presence, and the second is the allocation of business profits of multinational enterprises (MNEs) among the different jurisdictions where they operate….

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Active Ghosts: Nil-filing in Rwanda

Giulia Mascagni, Fabrizio Santoro, Denis Mukama, John Karangwa & Napthal Hakizimana

Nil-filing refers to taxpayers who report zero on all fields of their tax declaration. It is a largely ignored phenomenon in the tax literature, despite being well known to tax administrators. There is almost no evidence on the characteristics of nil-filers and the reasons for their apparently puzzling behaviour. This paper sheds light on this…

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January 2020

Addressing the Challenges of Taxation of the Digital Economy: Lessons for African Countries

Solomon Rukundo

The rapid growth of the digital economy in many African countries has led to concerns about whether their tax regimes are equipped to deal with this new phenomenon. The shift from a traditional bricks and mortar commercial environment to one that is electronic and information-based poses serious and substantial challenges to traditional tax regimes. African…

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January 2020

Fuel Subsidy Reform and the Social Contract in Nigeria: a Micro-economic Analysis

Neil McCulloch, Tom Moerenhout & Joonseok Yang

Fuel subsidies in Nigeria are enormous. At last estimate, the state subsidises petrol to the tune of US$3.9 billion – almost double the entire health budget. Such subsidies come at great cost: the opportunity costs of such spending on other development objectives are large; the distribution of resources to the state governments is reduced; the…

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December 2019

Review of Tax Treaty Practices and Policy Framework in Africa

Catherine Ngina Mutava

In recent years, tax treaties concluded by sub-Saharan African countries have become more residence-based with fewer provisions allocating taxing rights to the source countries. This trend is observed in treaties signed with OECD countries in particular. For countries which are capital importers, as is the case with most African countries, this means that these countries…

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September 2019

Tax Evasion and Missing Imports: Evidence From Transaction-Level Data

Andualem T. Mengistu, Kiflu G. Molla & Giulia Mascagni

It is well documented in the literature that developing countries raise less tax revenue as a share of their economy than their developed counterparts. Part of this gap can be explained by the relatively higher tax evasion in the former. Recent literature shows that increasing the availability of information reduces evasion, by increasing the probability…

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August 2019

Safe Harbour Regimes in Transfer Pricing: An African Perspective

Alexander Ezenagu

Applying transfer pricing rules in Africa poses great difficulties. There are few reliable comparables to benchmark prices and terms fixed by related entities in their transactions with each other. This means that jurisdictions struggle with applying the arm’s length principle in intra-firm dealings, as prescribed by tax treaties and domestic laws. Furthermore, the requirement for…

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July 2019

The Economics of Tobacco Control in Nigeria: Modelling the Fiscal and Health Effects of a Tobacco Excise Tax Change

Precious C. Akanonu, Joseph Ishaku & Chukwuka Onyekwena

This paper examines the potential for changes in the tobacco tax to contribute to raising government revenues, reducing tobacco use, and improving public health in Nigeria. Specifically, it estimates the impact of a change in the excise tax structure and level on cigarette consumption, government revenue, smoking prevalence, net-of-tax (NOT) revenue, and the excise tax…

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June 2019

Democratisation in Tanzania: No Elections Without Tax Exemptions

Ole Therkildsen & Dr Ane Karoline Bak

A demand-supply framework has been developed and applied to Tanzania to explore the link between democratisation, economic liberalisation and the use of tax exemptions to fund political parties’ electoral campaigns. In Tanzania, the demand for this type of money has increased since one-party rule was abolished in 1992. This led to reduced state subsidies to…

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