The central question we want to address is whether African countries should consider taxing profits from international shipping derived by non-resident shipping companies and which are the policy options available for them to do so. We believe the question fits in with current calls in international tax demanding for the re-evaluation of the century-old rules applied to allocate taxing rights on business profits across states. The debate was initially focused solely on the digitalized economy and fueled by the observation that the old rules which were drawn up to apply to brick-and-mortar business don’t capture value creation in digitalized business models.
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