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ATAF takes the lead on extractives taxation in Africa

Simon Osuji by Simon Osuji
June 30, 2025
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ATAF takes the lead on extractives taxation in Africa
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From 24-27 June 2025, the African Tax Administration Forum (ATAF) convened 40 tax administrators from across the continent in Pretoria, South Africa, for a landmark workshop on the effective taxation of the extractives industry. This is ATAF’s first standalone event focused on extractives – a sector with immense economic potential, yet one plagued by persistent revenue leakages.

Africa holds over 30% of the world’s mineral reserves, and the sector plays a central role in financing development. However, fiscal regimes, incentives, and complex legal frameworks have left many governments collecting far less than they should. For example, while mining makes up 10% of GDP and over 50% of exports in many resource, it generates just 2% in revenue, a signal of imbalanced value distribution.

Over four days, participants explored issues including:

• The extractives value chain and fiscal instruments,

• Legal and contractual arrangements in oil, gas, and mining,

• Production sharing agreements and royalty structures,

• Transfer pricing, offshore transactions, and tax avoidance,

• VAT, PIT, and CIT considerations unique to the industry, and

• International frameworks such as Pillar Two and tax treaty design.

This workshop forms part of ATAF’s growing focus on hard-to-tax sectors, including telecommunications and financial services, and reflects the organisation’s commitment to capacity building and technical leadership.

ATAF has already supported countries like Mozambique, Nigeria, and the DRC through the TIWB-ATAF programme, but this initiative goes a step further: creating a sustainable, continent-wide knowledge base for extractives taxation.



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