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ATAF’s Model Tax Agreement Under Review

Simon Osuji by Simon Osuji
April 29, 2025
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The ATAF Model Tax Agreement serves as a guiding instrument to help African nations negotiate treaties that better protect their interests, ensure fair allocation of taxing rights, and enhance domestic revenue mobilisation.

The African Tax Administration Forum (ATAF) has embarked on an important initiative: the revision of its Model Tax Agreement, with the aim of strengthening Africa’s position in international tax treaty negotiations.

Historically, many African countries have entered into tax treaties based on global models that do not always reflect the unique economic realities and developmental priorities of the continent. These treaties can unintentionally limit domestic revenue potential by ceding key taxing rights to residence countries, typically more developed economies.

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The ATAF Model Tax Agreement serves as a guiding instrument to help African nations negotiate treaties that better protect their interests, ensure fair allocation of taxing rights, and enhance domestic revenue mobilisation. As the global tax landscape evolves, particularly with recent developments on the taxation of the digital economy and base erosion, the need to update and refine this model has become ever more pressing.

To lead this effort, ATAF has established a dedicated Working Party, composed of experienced tax professionals from the
Federal Inland Revenue Service of Nigeria,
Kenya Revenue Authority,
Zambia Revenue Authority,
Rwanda Revenue Authority and
Tanzania Revenue Authority. This diverse group brings regional insights and technical expertise to the task of developing a more responsive and inclusive model.

The Committee is charged with incorporating African tax policy perspectives, addressing emerging global tax challenges, and ensuring the model aligns with ATAF’s strategic objective of supporting member countries in securing sustainable tax revenue.



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