Africa Tax In Brief - 14 July 2026

• Published date: 22 July 2026
• Subject Matter: Tax, Transfer Pricing, Corporate Tax, Sales Taxes: VAT, GST
• Law Firm: ENS
• Author: Ms Celia Becker

ANGOLA: Additional tax incentives for oil blocks approved

On 22 June 2026, the Council of Ministers approved proposals authorising the President to enact Presidential Legislative Decrees granting targeted tax incentives for the concession areas of Blocks 33/24 for Chevron, 17/25 and 32/21 for TotalEnergies, and 19 for British Petroleum (BP). The Presidential Legislative Decrees, aimed at improving the competitiveness of marginal fields and deepwater blocks, need to be formally enacted following the authorisation process.

The new incentives include:

• Enhanced tax benefits for operators in both new and existing oil blocks, such as reductions in tax rates and improved terms under Production Sharing Agreements;
• Extensions of tax holidays, accelerated depreciation regimes; and
• Targeted relief on import duties and other indirect taxes related to exploration and development activities.

ANGOLA: Personal Income Tax Code passed by National Assembly Specialised Working Committee

Angola's National Assembly Specialised Working Committee approved the draft Law introducing the unified Personal Income Tax Code (Código do Imposto sobre os Rendimentos de Pessoas Singulares, IRPS) on 16 June 2026.

The Tax Code, which will enter into force on 1 January 2027 following its promulgation by the President, will replace the current fragmented system with a single modern framework covering all personal income categories, including employment, business/professional, capital, real estate, and capital gains.

ANGOLA: 5% special tourism contribution introduced

On 30 April 2026, Angola issued Presidential Legislative Decree No. 4/26, introducing a special tourism contribution (Contribuição Especial para o Turismo, (“CET”)) at a rate of 5%. The Decree, which will enter into force 90 days after publication, applies only to international tourists aged 12 years and above who stay in tourist resorts or local accommodation establishments.

The contribution is charged at 5% of the daily room rate per overnight stay, up to a maximum of seven nights and is due at the time of check-in or check-out of the tourist resort or local accommodation establishment. It must be clearly shown on the invoice.

Accommodation providers are responsible for:

• Collecting the CET and remitting the amounts to the competent authority by the last business day of the month following the month in which it was collected; and
• Maintaining auditable records of all collections, including invoices, receipts, monthly collection maps, credit notes and any additional information as may be required by the tax authority.

BENIN: 8% increase in State Budget approved in draft 2026 Amending Finance Law

Following the restructuring of the government administration, on 3 June 2026 Benin's Council of Ministers approved a draft 2026 Amending Finance Law increasing the state budget by 8% compared to the initial finance law. The draft 2026 Amending Finance Law is currently under consideration by the National Assembly.

BOTSWANA: 2026 Tax Law amendments gazetted

On 30 June 2026, The Income Tax Act, 2026 (Act 13 of 2026), Tax Administration Act, 2026 (Act 14 of 2026), Value Added Tax (“VAT”) Act, 2026 (Act 15 of 2026) and Customs (Amendment) Act, 2026 (Act 16 of 2026) were gazetted and, together with a suite of supporting statutory instruments, came into effect on 1 July 2026 (subject to a few exceptions under the VAT Act). Significant amendments include:

• Increasing the corporate income tax rate to 24.5%, with mining companies being taxed at the variable mining rate (the higher of a statutory formula or 24.5%). Diamond mining companies in which the Government holds an equity interest will pay the 24.5% flat rate;
• Increasing the top marginal income tax rate for resident individuals earning taxable income exceeding BWP400 000 to 27.5%;
• Revoking the 1990 Employment Income Regulations and replacing them with a comprehensive new benefit valuation framework for employee benefits, including housing, motor vehicles, school fees, and utilities;
• Introducing the Income Tax (Transfer Pricing) Regulations, 2026 (Statutory Instrument No. 189);
• Providing that where a taxpayer makes a partial payment against a combined tax, interest and penalty liability, the payment is applied first against the tax, then against the late payment interest, and finally against the penalty (the opposite of the previous allocation order);
• Providing that the electronic billing system will commence nine months from the date of commencement of the Tax Administration Act (approximately 1 April 2027); and
• Requiring companies carrying on a relevant business to file a substance report with the Commissioner General within three months of the end of the tax year, setting out the company's core income-producing activities, management body composition, employees, expenditure and physical presence in Botswana.

BOTSWANA: Regulations for government entities and large unregistered persons concerning VAT reverse charge supplies issued

On 29 May 2026, Botswana issued the VAT (Government Entities and Large Unregistered Persons) Regulations 2026 (Statutory Instrument No. 73 of 2026), prescribing registration and compliance requirements for government entities and large unregistered persons concerning reverse-charged supplies under the VAT (Amendment) Act No. 16 of 2025.

The Regulations require government entities and large unregistered persons to:

• Apply for VAT registration and account for reverse-charge supplies. Applications must be made in a prescribed form and should include
  • the registered name of the government entity or large unregistered person;
  • the address, telephone number and electronic contact details of the applicant;
  • details of the business activities or functions carried out by the applicant; and
  • the name and contact details of the person responsible for VAT compliance;
  • a letter from an accounting officer or a board resolution approving the registration;
• Make all VAT registration applications within two months from the commencement of the VAT (Amendment) Act, 2025 and
• Begin accounting for reverse-charged supplies upon the expiry of the two-month transitional period (August 2026).

BOTSWANA: Implementation timelines for VAT on remote services outlined

On 29 May 2026, the Botswana Unified Revenue Service (“BURS”) published a public notice outlining the implementation timelines, registration windows and filing deadlines for the VAT (Amendment) Act No. 16 of 2025, which became effective on 1 June 2026, introducing a tax framework for remote services supplied by non-resident providers.

The VAT Amendment Act had been enacted in October 2025, introducing new provisions relating to remote services, electronic marketplaces, reverse charge obligations and electronic tax administration measures. The notice provides that:

• Registration for non-resident suppliers of remote services commenced on 1 June 2026. Affected non-resident suppliers must officially begin charging VAT on their taxable supplies on 1 October 2026;
• Government entities and large unregistered persons with annual turnover exceeding BWP1-million must commence tax registration from 1 August 2026. Existing registered persons must begin accounting for reverse-charged supplies of remote services from 1 August 2026; and
• Supplies imported before transitioning into the new reporting framework must continue to be reported via the declaration of value added tax due on imported service (Form VAT.017.1);

On the same date, the BURS issued the VAT (Remote Services) Regulations 2026 (Statutory Instrument No. 74 of 2026), establishing the administrative framework for the taxation of remote services supplied by non-resident service providers and electronic marketplace operators. The Regulations include:

• The scope of remote services supplied into Botswana;
• The requirements for the application and registration for VAT. Upon registration, the Commissioner General will issue the supplier with a VAT registration number;
• Required documents to accompany the registration;
• The requirement that
  • VAT returns must be submitted and VAT paid on or before the 25^th day of the month following the end of the relevant tax period;
  • Registered suppliers must issue electronic tax invoices showing the recipient's name and VAT registration number and maintain invoices and records for at least five years;
• Remote service suppliers may appoint representatives to fulfil their VAT obligations, including filing returns and remitting tax. The appointment must be notified to the Commissioner General;
• Remote service suppliers making supplies to VAT-registered customers are required to obtain the customer's VAT registration number;
• Registered suppliers must issue electronic tax invoices showing the recipient's name and VAT registration number; and
• As a transitional measure, suppliers that are liable to register under the remote services provisions are required to register immediately upon commencement of the VAT Act (June 2026). Such suppliers are required to begin charging VAT four months after registration (October 2026).

BURKINA FASO: Local country-by-country reporting obligation suspended

Circular No.2026-02020/MEF/SG/DGI, issued on 29 June 2026, announced the suspension of the local filing obligation for country-by-country (“CbC”) reports for companies operating in the country during the 2023, 2024 and 2025 fiscal years due to technical constraints.

The suspension applies to companies required to file a CbC report under article 98-2(2) and (3) of the General Tax Code (Code général des impôts, CGI) where the company is:

• Held directly or indirectly by an entity established in a jurisdiction that does not require CbC reporting but that would be required to file if established in Burkina Faso;
• Held directly or indirectly by an entity established in a jurisdiction not included on the list provided for under article 98-2(8) of the CGI but with which Burkina Faso has concluded a tax information exchange agreement; or
• Held...