Connect with us

Feature/OPED

New Global Tax Rules to Address Imbalances in Africa’s Tax Revenue

Published

on

Africa's Tax Revenue

By Denny Da Silva

One hundred and thirty-six of the 140 members of the OECD G20 Inclusive Framework, including South Africa, have agreed on a new set of global tax rules that will reform the world’s tax system.

Notably, two African countries that are members of the Inclusive Framework have not yet joined the agreement – Kenya and Nigeria.

The two-pillar system will be presented to the G20 Leaders’ Summit at the end of October 2021. It will result in a reallocation of taxing rights from resident to source countries of certain multinational enterprises (MNEs), if thresholds are met, in addition to a 15 per cent global minimum tax rate for certain organizations, implemented from 2023. The agreement aims to redress global tax revenue imbalances and is set to benefit developing economies in Africa.

According to African policymakers, a multilateral approach to tax collection has numerous benefits for the continent. Smaller economies like those in Africa are more reliant on business income tax than larger economies.

The African Tax Administration Forum (ATAF) previously noted that 16 per cent of total tax revenue in African countries is from corporate tax, compared to 9 per cent in OECD countries.

African countries have increased their revenue collection methods and have implemented punitive measures to clamp down on tax avoidance measures because the revenue collected is of the utmost importance to the stability of their economies. But current tax rules have meant that African countries could not collect tax revenue from multinationals, even if they were operating profitably in their countries.

The OECD’s Pillar One changes enable market jurisdictions to charge income tax on a portion of the profits of large multinational companies operating within their borders. It will reallocate taxing rights from their resident countries to markets where they conduct business and generate profits, regardless of their physical presence in that country.

Pillar One will apply to MNEs with sales over €20 billion and that generate a net profit above 10 per cent (profit before tax/turnover). Amount A has been confirmed at 25 per cent of an MNE’s residual profit (i.e. profit in excess of 10 per cent of revenue) and will be allocated to market jurisdictions with sufficient nexus using a revenue-based allocation key – being a revenue of at least €1 million from that jurisdiction (or at least €250,000 for jurisdictions with a GDP of less than €40 billion).

No agreement has yet been reached on the implementation and design of Amount B, which intends to simplify the arm’s length principle for baseline marketing and distribution activities, but the intention is for this to be completed in 2022.

Pillar Two proposes a new network of rules that will reallocate taxing rights according to a new global minimum tax regime of 15 per cent – aimed at ensuring a minimum effective net tax rate across all jurisdictions. It will apply to all enterprises generating revenue above €750 million. Model rules for bringing Pillar Two into domestic legislation will be introduced in 2022 and become effective in 2023.

On the African front, ATAF submitted proposals to the OECD on the new agreement and announced in October 2021 that many of its proposals were incorporated into Pillar One, including broadening the agreement to incorporate all sectors but excluding the extractives sector. ATAF stated that resource-rich African countries price their minerals on their “inherent characteristics” and not on “market intangibles”, and as such, taxing rights should go to the resource-producing country.

ATAF further noted that their request for greater simplification of some of the rules was also incorporated. Specifically, the nexus threshold was reduced to €1 million, down from €5 million, with a lower threshold of €250 000 for smaller jurisdictions with GDPs lower than €40 billion and no “plus factors.” ATAF also secured an elective binding dispute resolution mechanism, as opposed to the existing mandatory dispute resolution process, for eligible developing countries.

ATAF was also pleased that the Subject to Tax Rule (STTR) would be a minimum standard that developing countries can require to be included in bilateral tax treaties with Inclusive Framework members and that the STTR would cover interest, royalties, and a defined set of other payments.

However, there was disappointment that the agreement only allocates 25 per cent of the residual profit to market jurisdictions under Amount A – ATAF had advocated for this to be 35 per cent.

African countries now have until 2023 to implement the new tax rules, navigating difficulties with regard to tax implementation due to capacity challenges and issues with how the rules will impact countries that are not members of the Inclusive Framework.

However, the OECD has stated it will ensure the rules can be effectively and efficiently administered and that they will offer comprehensive capacity-building support to countries that need it.

Overall, the global tax changes are good news for the continent and are expected to result in increased tax revenue for African countries at a time when capital is direly needed for post-pandemic recovery.

Denny Da Silva is the Associate Director of Tax at Baker McKenzie, Johannesburg, South Africa

Advertisement
1 Comment

Leave a Reply

Your email address will not be published. Required fields are marked *

Feature/OPED

Turning Stolen Hardware into a Data Dead-End

Published

on

Apu Pavithran Turning Stolen Hardware

By Apu Pavithran

In Johannesburg, the “city of gold,” the most valuable resource being mined isn’t underground; it’s in the pockets of your employees.

With an average of 189 cellphones reported stolen daily in South Africa, Gauteng province has become the hub of a growing enterprise risk landscape.

For IT leaders across the continent, a “lost phone” is rarely a matter of a misplaced device. It is frequently the result of a coordinated “snatch and grab,” where the hardware is incidental, and corporate data is the true objective.

Industry reports show that 68% of company-owned device breaches stem from lost or stolen hardware. In this context, treating mobile security as a “nice-to-have” insurance policy is no longer an option. It must function as an operational control designed for inevitability.

In the City of Gold, Data Is the Real Prize

When a fintech agent’s device vanishes, the $300 handset cost is a rounding error. The real exposure lies in what that device represents: authorised access to enterprise systems, financial tools, customer data, and internal networks.

Attackers typically pursue one of two outcomes: a quick wipe for resale on the secondary market or, far more dangerously, a deep dive into corporate apps to extract liquid assets or sellable data.

Clearly, many organisations operate under the dangerous assumption that default manufacturer security is sufficient. In reality, a PIN or fingerprint is a flimsy barrier if a device is misconfigured or snatched while unlocked. Once an attacker gets in, they aren’t just holding a phone; they are holding the keys to copy data, reset passwords, or even access admin tools.

The risk intensifies when identity-verification systems are tied directly to the compromised device. Multi-Factor Authentication (MFA), widely regarded as a gold standard, can become a vulnerability if the authentication factor and the primary access point reside on the same compromised device. In such cases, the attacker may not just have a phone; they now have a valid digital identity.

The exposure does not end at authentication. It expands with the structure of the modern workforce.

65% of African SMEs and startups now operate distributed teams. The Bring Your Own Device (BYOD) culture has left many IT departments blind to the health of their fleet, as personal devices may be outdated or jailbroken without any easy way to know.

Device theft is not new in Africa. High-profile incidents, including stolen government hardware, reinforce a simple truth: physical loss is inevitable. The real measure of resilience is whether that loss has any residual value. You may not stop the theft. But you can eliminate the reward.

Theft Is Inevitable, Exposure is Not

If theft cannot always be prevented, systems must be designed so that stolen devices yield nothing of consequence. This shift requires structured, automated controls designed to contain risk the moment loss occurs.

Develop an Incident Response Plan (IRP)
The moment a device is reported missing, predefined actions should trigger automatically: access revocation, session termination, credential reset and remote lock or wipe.

However, such technical playbooks are only as fast as the people who trigger them. Employees must be trained as the first line of defence —not just in the use of strong PINs and biometrics, but in the critical culture of immediate reporting. In high-risk environments, containment windows are measured in minutes, not hours.

Audit and Monitor the Fleet Regularly

Control begins with visibility. Without a continuous, comprehensive audit, IT teams are left responding to incidents after damage has occurred.

Opting for tools like Endpoint Detection and Response (EDR) allows IT teams to spot subtle, suspicious activities or unusual access attempts that signal a compromised device.

Review Device Security Policies
Security controls must be enforced at the management layer, not left to user discretion. Encryption, patch updates and screen-lock policies should be mandatory across corporate devices.

In BYOD environments, ownership-aware policies are essential. Corporate data must remain governed by enterprise controls regardless of device ownership.

Decouple Identity from the Device
Legacy SMS-based authentication models introduce avoidable risk when the authentication channel resides on the compromised handset. Stronger identity models, including hardware tokens, reduce this dependency.

At the same time, native anti-theft features introduced by Apple and Google, such as behavioural theft detection and enforced security delays, add valuable defensive layers. These controls should be embedded into enterprise baselines rather than treated as optional enhancements.

When Stolen Hardware Becomes Worthless

With POPIA penalties now reaching up to R10 million or a decade of imprisonment for serious data loss offences, the Information Regulator has made one thing clear: liability is strict, and the financial fallout is absolute. Yet, a PwC survey reveals a staggering gap: only 28% of South African organisations are prioritising proactive security over reactive firefighting.

At the same time, the continent is battling a massive cybersecurity skills shortage. Enterprises simply do not have the boots on the ground to manually patch every vulnerability or chase every “lost” terminal. In this climate, the only viable path is to automate the defence of your data.

Modern mobile device management (MDM) platforms provide this automation layer.

In field operations, “where” is the first indicator of “what.” If a tablet assigned to a Cape Town district suddenly pings on a highway heading out of the city, you don’t need a notification an hour later—you need an immediate response. An effective MDM system offers geofencing capabilities, automatically triggering a remote lock when devices breach predefined zones.

On Supervised iOS and Android Enterprise devices, enforced Factory Reset Protection (FRP) ensures that even after a forced wipe, the device cannot be reactivated without organisational credentials, eliminating resale value.

For BYOD environments, we cannot ignore the fear that corporate oversight equates to a digital invasion of personal lives. However, containerization through managed Work Profiles creates a secure boundary between corporate and personal data. This enables selective wipe capabilities, removing enterprise assets without intruding on personal privacy.

When integrated with identity providers, device posture and user identity can be evaluated together through multi-condition compliance rules. Access can then be granted, restricted, or revoked based on real-time risk signals.

Platforms built around unified endpoint management and identity integration enable this model of control. At Hexnode, this convergence of device governance and identity enforcement forms the foundation of a proactive security mandate. It transforms mobile fleets from distributed risk points into centrally controlled assets.

In high-risk environments, security cannot be passive. The goal is not recovery. It is irrelevant, ensuring that once a device leaves authorised hands, it holds no data, no identity leverage, and no operational value.

Apu Pavithran is the CEO and founder of Hexnode

Continue Reading

Feature/OPED

Daniel Koussou Highlights Self-Awareness as Key to Business Success

Published

on

Ambassador Daniel Kossouno

By Adedapo Adesanya

At a time when young entrepreneurs are reshaping global industries—including the traditionally capital-intensive oil and gas sector—Ambassador Daniel Koussou has emerged as a compelling example of how resilience, strategic foresight, and disciplined execution can transform modest beginnings into a thriving business conglomerate.

Koussou, who is the chairman of the Nigeria Chapter of the International Human Rights Observatory-Africa (IHRO-Africa), currently heads the Committee on Economic Diplomacy, Trade and Investment for the forum’s Nigeria chapter. He is one of the young entrepreneurs instilling a culture of nation-building and leadership dynamics that are key to the nation’s transformation in the new millennium.

The entrepreneurial landscape in Nigeria is rapidly evolving, with leaders like Koussou paving the way for innovation and growth, and changing the face of the global business climate. Being enthusiastic about entrepreneurship, Koussou notes that “the best thing that can happen to any entrepreneur is to start chasing their dreams as early as possible. One of the first things I realised in life is self-awareness. If you want to connect the dots, you must start early and know your purpose.”

Successful business people are passionate about their business and stubbornly driven to succeed. Koussou stresses the importance of persistence and resilience. He says he realised early that he had a ‘calling’ and pursued it with all his strength, “working long weekends and into the night, giving up all but necessary expenditures, and pressing on through severe setbacks.”

However, he clarifies that what accounted for an early success is not just tenacity but also the ability to adapt, to recognise and respond to rapidly changing markets and unexpected events.

Ambassador Koussou is the CEO of Dau-O GIK Oil and Gas Limited, an indigenous oil and natural gas company with a global outlook, delivering solutions that power industries, strengthen communities, and fuel progress. The firm’s operations span exploration, production, refining, and distribution.

Recognising the value of strategic alliances, Koussou partners with business like-minds, a move that significantly bolsters Dau-O GIK’s credibility and capacity in the oil industry. This partnership exemplifies the importance of building strong networks and collaborations.

The astute businessman, who was recently nominated by the African Union’s Agenda 2063 as AU Special Envoy on Oil and Gas (Continental), admonishes young entrepreneurs to be disciplined and firm in their decision-making, a quality he attributed to his success as a player in the oil and gas sector. By embracing opportunities, building strong partnerships, and maintaining a commitment to excellence, Koussou has not only achieved personal success but has also set a benchmark for future generations of African entrepreneurs.

His journey serves as a powerful reminder that with determination and vision, success is within reach.

Continue Reading

Feature/OPED

Pension for Informal Workers Nigeria: Bridging the Pension Gap

Published

on

Timi Olubiyi Price of Fake Life

***The Case for Informal Sector Pensions in Nigeria
***A Crucial National Conversation

By Timi Olubiyi, PhD

In Nigeria today, the phrase “pension” evokes many different mixed reactions. For many civil servants and people in the corporate world, it conjures a bit of hope, but for the majority in the informal sector, who are in the majority in Nigeria, it is bleak. Millions of Nigerians are facing old age without any financial security due to a lack of retirement plans and a stable pension plan. Particularly, the millions who operate in markets, corner shops, transportation, agriculture, and loads of the nano and micro scale enterprises operators are without pension plans or retirement hope.

From the observation of the author and available records, staggering around 90 per cent of Nigeria’s workforce operates in the informal economy. Yet current pension coverage for this group is virtually non-existent. As observed, the absence of meaningful pension participation by this class of worker reinforces the vulnerability, intensifies poverty among older people, and puts pressure on families who are ill-equipped to shoulder the burden.

The significance of having a pension plan for informal workers in Nigeria, given the large number of people in that sector and the high level of unemployment and underemployment, cannot be overstated. As it is deeply connected to sustenance and the level of poverty in the country. Pension for informal workers in Nigeria is not just a technical policy matter; it is a story about dignity, security, and whether a lifetime of hard work ends in rest or in desperation.

Nigeria’s pension system, primarily structured around the Contributory Pension Scheme (CPS) managed by the National Pension Commission (PenCom), has made significant progress for formal sector employees, yet the large portion of the informal workforce which are traders, artisans, okada riders, small-scale farmers, domestic workers, and gig economy participants who drive the real engine of the economy.

Though the Micro Pension Plan (MPP) was launched in 2019, which is intended to provide a voluntary contributory framework for informal workers, its uptake has been underwhelming; after several years, only a fraction of the millions targeted have enrolled, and far fewer contribute actively. One big reason for this is that, unlike formal workers who receive regular salaries and have employers who deduct and remit pension contributions, informal workers face irregular incomes, a lack of documentation, limited financial literacy, and deep mistrust of government institutions, making traditional pension models ill-suited for their realities.

Moreso the informal worker most times live on day-to-day income. For instance, a motorcycle rider in Lagos who earns ₦14,000 on a good day but must pay for fuel, bike maintenance, police “settlements,” and family expenses, how can he realistically commit to a monthly pension contribution when his income fluctuates wildly? So, the Micro Pension Plan for the informal sector participation will remain low due to poor awareness, complex processes, lack of tailored contribution flexibility, and limited trust.

To truly make pensions work for informal workers, Nigeria must rethink the system from the ground up, designing it around the lived realities of its people rather than forcing them into rigid formal-sector structures. First, the government should introduce a co-contributory model where the state matches a percentage of informal workers’ savings, similar to what is practised in some European countries, turning pension contributions into a powerful incentive rather than a burdensome obligation.

Second, digital technology must be leveraged aggressively—mobile-based pension platforms linked to BVN or NIN could allow daily, weekly, or micro-contributions as small as ₦100, integrating seamlessly with fintech apps like OPay, Paga, or bank USSD services so that saving becomes as easy as buying airtime.

Third, automatic enrollment through cooperatives, trade unions, market associations, and transport unions could significantly expand coverage, with opt-out rather than opt-in mechanisms to counter human inertia.

Fourth, financial literacy campaigns in local languages via radio, community leaders, and religious institutions are essential to rebuild trust and demonstrate that pensions are not a “government scam” but a personal safety net.

Fifth, Nigeria should consider a universal social pension for elderly citizens who never participated in formal or informal schemes, modelled after systems in countries like Denmark and the Netherlands, ensuring that no Nigerian dies in poverty simply because they worked outside formal structures.

Sixth, investment strategies for pension funds must prioritise both security and development—allocating a portion to infrastructure projects that create jobs, improve power supply, and stimulate economic growth while maintaining prudent risk management.

Seventh, inflation protection should be built into pension payouts so that retirees’ purchasing power is not eroded by Nigeria’s volatile economy.

Eighth, the system must be inclusive of women, who dominate the informal sector yet often lack property rights or formal identification, by simplifying documentation requirements and providing gender-sensitive outreach.

Ninth, limited emergency withdrawal options could be introduced—strictly regulated—to help contributors handle crises without abandoning the system entirely.

Finally, transparency and accountability are non-negotiable; regular public reporting, independent audits, and user-friendly dashboards would strengthen confidence that contributions are safe and growing. If Nigeria can blend its innovative spirit with lessons from global best practices—combining Denmark’s social security ethos, Singapore’s savings discipline, and Canada’s inclusivity—it could transform the lives of millions of informal workers who currently face retirement with fear rather than hope.

Imagine Aisha, years from now, closing her market stall not in exhaustion and anxiety but in calm assurance that her pension will cover her basic needs; imagine Tunde hanging up his helmet knowing he can afford healthcare and shelter; imagine Ngozi harvesting not just crops but the fruits of a lifetime of secure savings. The suspense that hangs over the future of Nigeria’s informal workers can be resolved, but only if policymakers act boldly, creatively, and compassionately—because a nation that allows its hardest workers to age in poverty is a nation that undermines its own prosperity, while a nation that secures their retirement builds not just pensions, but peace.

Hope comes from innovation. Fintech-powered pension models that allow small, frequent contributions similar to informal savings associations like esusu offer ways to integrate pensions into existing savings cultures. Making pension contributions compatible with mobile money and agent networks could drastically reduce barriers to entry. Hope comes from public education. Building financial literacy campaigns, partnering with community leaders, marketplaces, trade associations, and digital platforms can help shift perceptions. A pension should be understood not as a distant bureaucratic programme, but as future self-insurance and dignity

The significance of having a pension plan for informal workers in Nigeria, given its large informal sector and high level of unemployment and underemployment, cannot be overstated, as it is deeply connected to social stability, economic sustainability, poverty reduction, and national development.

First, from a social protection and human dignity perspective, a pension plan for informal workers is critical because it provides a safety net for old age. Nigeria’s informal sector includes traders, artisans, mechanics, tailors, hairdressers, okada riders, gig workers, domestic workers, small-scale farmers, and street vendors, many of whom work hard throughout their lives but have no formal retirement benefits. Without a pension, these individuals often become completely dependent on their children, relatives, or charity in old age, which can strain families and increase intergenerational poverty. A well-structured pension system ensures that ageing informal workers can maintain a basic standard of living, access healthcare, and avoid extreme deprivation, thereby preserving their dignity and reducing elderly vulnerability.

Second, from an economic stability and poverty reduction standpoint, pensions play a crucial role in reducing old-age poverty. Nigeria already struggles with high poverty levels, and a large proportion of elderly citizens without income support exacerbates this problem. When informal workers lack pension savings, they continue working well into old age, often in physically demanding jobs, which reduces productivity and increases health risks. A pension system allows for smoother retirement transitions, reduces reliance on welfare, and ensures that older citizens remain consumers rather than economic burdens, thereby sustaining economic activity.

Third, pensions for informal workers are significant for financial inclusion and savings culture. Many Nigerians in the informal sector operate primarily in cash and have limited engagement with formal financial institutions. A pension plan tailored to informal workers, especially one integrated with mobile money and digital platforms, can encourage regular saving, improve financial literacy, and bring millions of people into the formal financial system. This, in turn, strengthens Nigeria’s overall financial sector and increases the pool of domestic savings available for investment in infrastructure, businesses, and development projects.

Fourth, the significance is evident in reducing dependence on government emergency support. Currently, the Nigerian government often has to intervene with ad-hoc social assistance programs, especially during crises such as the COVID-19 pandemic, inflation shocks, or economic downturns. If informal workers had functional pension savings, they would be better able to absorb economic shocks in retirement without relying heavily on government aid, reducing fiscal pressure on the state.

Fifth, pensions for informal workers contribute to intergenerational equity and family stability. In Nigeria, many elderly parents depend on their working children for survival, which places financial strain on younger generations who may already be struggling with unemployment, housing costs, and education expenses. A pension system reduces this burden, allowing younger Nigerians to invest in their own futures rather than being trapped in a cycle of supporting ageing relatives without external assistance.

Sixth, from a national development perspective, including informal workers in the pension system strengthens Nigeria’s long-term economic planning. Pension funds represent large pools of capital that can be invested in critical sectors such as housing, energy, transportation, and manufacturing. If millions of informal workers contribute even in small amounts, this could significantly expand Nigeria’s pension fund assets, providing stable, long-term financing for development projects that create jobs and stimulate growth.

Seventh, pensions for informal workers are important for gender equity, because women dominate many informal occupations in Nigeria, such as petty trading, market vending, tailoring, and caregiving roles. These women often have lower lifetime earnings, limited access to formal employment, and fewer assets. A targeted informal sector pension scheme can protect elderly women from destitution and reduce gender-based economic inequality in old age.

Eighth, the significance is also linked to public trust and governance. A transparent, accessible, and reliable pension system for informal workers can strengthen citizens’ trust in government institutions. Many informal workers currently distrust government programs due to past corruption, failed schemes, or poor implementation. A well-functioning pension plan that delivers real benefits would demonstrate that the state values all citizens, not just formal sector employees.

Lastly, given Nigeria’s demographic reality of a large and growing population, failing to integrate informal workers into a pension framework poses serious long-term risks. As life expectancy increases, the number of elderly Nigerians will rise significantly in the coming decades. Without a structured pension system for informal workers, Nigeria could face a severe old-age crisis characterised by mass poverty, social unrest, and increased pressure on healthcare and social services.

In summary, having a pension plan for informal workers in Nigeria is significant because it promotes social security, reduces poverty, enhances financial inclusion, supports economic stability, eases intergenerational burdens, strengthens national development, promotes gender equity, builds public trust, and prepares the country for its ageing population. For a nation where the majority of workers are informal, excluding them from pension coverage is not just an oversight; it is a major structural weakness that must be urgently addressed for Nigeria’s long-term prosperity and social cohesion.

Continue Reading

Trending