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

Nigeria’s CPI Rebase Broke the Data: Here’s What the Unbroken Picture Actually Shows

Published

on

Nigeria’s CPI Rebase

By Ejiye Jimeta Ibhawoh

When the NBS rebased the Consumer Price Index in February 2025, and headline inflation fell overnight from 34.80% to 24.48%, yields compressed, and fixed income rallied. A question that should have been straightforward became almost impossible to answer: what is cash actually earning in Nigeria after inflation?

We know what the commentary said. Statistical fix or economic illusion. Cost of living still high. Basket weights shifted. All true, all well-covered. But nobody did the obvious next thing: build the bridge between the old series and the new one, then show what a continuous 15-year picture of Nigerian real returns actually looks like. We did.

The problem with two CPI series

The old NBS CPI ran from a November 2009 base, 740 items weighted by the 2003/04 Nigeria Living Standards Survey. The new methodology uses a 2024 average base, 934 items, and 2023 weights. Food and non-alcoholic beverages dropped from 51.8% to 40.1%. Restaurants and accommodation surged from 1.2% to 12.9%. A 13th COICOP division was added (Insurance and Financial Services). That alone tells you how much the consumption basket has shifted.

These are legitimate improvements. Nigeria’s spending patterns have genuinely changed since 2009. Nobody disputes that.

The problem is continuity. NBS published no officially chain-linked historical series. The old index ends in December 2024. The new one picks up in January 2025. Month-on-month rates don’t match across the boundary. Stops & Gaps documented a particularly egregious discontinuity: the rebased index implies prices fell 12.3% in a single month in December 2024. The largest actual single-month decline since 1995 was 3.5%.

For anyone maintaining a time series (pension fund benchmarking, fixed income attribution, real return measurement), the data is broken. Every analyst in Lagos knows this. Most shrugged and moved on.

Chain-linking: what we built and why

We followed the IMF CPI Manual, Chapter 9, for linking series across base-period changes. December 2024 is the overlap month where both old-base and new-base CPI levels exist. The chain-linking factor comes out at 0.11523. We rescaled the entire old series onto the new base.

The result: 204 continuous monthly CPI observations from February 2009 to January 2026. One hundred and ninety-one back-tested months on the old base, spliced to 13 live months on the new base. No interpolation. No estimation. Month-on-month rates are preserved through the splice point, and every calculation is reproducible from published NBS and CBN data.

We paired this CPI series with CBN 91-day T-bill stop rates from primary auctions to construct the VNG-CRR, the Venoble Nigeria Cash Real Return Index. Two inputs per month. NBS CPI level. CBN stop rate. Fisher equation. All compounds into an index.

The headline: over 204 months, Nigerian cash earned +9.48% annualised in nominal terms and −5.48% annualised in real terms. This is consistent, cumulative, and structural purchasing power destruction.

Put it differently. N1 million placed in 91-day T-bills in February 2009 would be worth roughly N4.7 million as of January 2026 in nominal terms. Adjust for what that money can actually buy, and the real value is closer to N380,000. The T-bill investor multiplied his digits and shrank his wealth.

Why this matters now

Start with pension fund allocation. Nigeria’s pension assets reached N26.66 trillion as of October 2025. Roughly 60% (c.N16 trillion) sits in FGN securities. If the annualised real return on government paper has been negative for 15 consecutive years, what does that mean for 10 million contributor accounts? The OECD flagged this in its 2024 pension report using 2023 data. Pension funds in Nigeria, Angola, and Egypt, where more than half of assets sit in bills and bonds, delivered negative real returns. PenCom raised equity limits in February 2026: RSA Fund I from 30% to 35%, RSA Fund II from 25% to 33% and while this is indeed a step in the right direction, it is not enough.

Then there is the visibility problem. Under the old methodology, a 91-day bill at 18% against 34.8% inflation was obviously underwater. Under the new CPI, the same bill at 15% against 15.15% inflation looks like a break-even. Did real returns improve, or did the statistical agency change the yardstick? In our view, both. Inflation has genuinely decelerated: monthly CPI growth dropped below 1.0% for several consecutive months in H2 2025. But the rebase also flatters the comparison by c.10 percentage points. Without a continuous series, you cannot separate the two effects.

And the sign has flipped. This is not speculation. From August 2025 through January 2026, the VNG-CRR recorded six consecutive months of positive real returns. January 2026 was the strongest at +4.39% real. Month-on-month CPI fell 2.88% while the nominal T-bill return was 1.38%. The real index climbed from

984 to 1,027, above its inception base of 1,000 for the first time.

After 15 years of negative returns, real returns have turned positive. Whether that holds is the question nobody can answer yet.

What we do not know

We don’t have a strong view on the persistence of the disinflation trend. The December 2025 CPI base effect is messy. The rebased December 2024 level was set at 100, which creates arithmetic distortions in year-on-year comparisons as that month rotates out. Headline YoY inflation could spike artificially in December 2025 data even if underlying prices remain stable. Anyone anchoring allocation decisions to year-on-year headline numbers will get whipsawed.

We also cannot tell you whether the new CPI basket accurately captures the cost-of-living reality for the median Nigerian. Restaurants and accommodation at 12.9% may reflect urban middle-class spending in Victoria Island and Wuse. It does not reflect what a civil servant in Kano or a smallholder farmer in Benue pays for food and transport. The CPI measures what it measures. It is not a cost-of-living index. That distinction matters more than most post-rebase commentary acknowledged, and it is the gap a continuous real return series is designed to fill.

The allocation question

Here is what the data does tell you. Over 204 months, the real return hurdle rate (what an alternative investment must beat just to match cash in purchasing-power terms) has been low. Negative, in fact. Any asset class generating positive real returns has beaten cash. Equities: the NGX ASI returned 51.19% in 2025. Real estate in Lekki and Abuja CBD. Dollar-denominated instruments accessed through NAFEM. All cleared the hurdle.

With real yields now positive, the calculus shifts. Cash is no longer guaranteed wealth destruction. But 15 years of compounded losses do not reverse in six months. The real index is at 1,027. It needs sustained positive real returns to recover the purchasing power lost over the prior decade.

For pension fund administrators and asset managers, the implication is straightforward: measure everything against the real return on cash. Not nominal yields. Not headline inflation. The actual, chain-linked, continuously compounded purchasing-power return. If your portfolio is not beating that number, you are losing money regardless of what the nominal statement says.

Why independent benchmarks matter

Nigeria has the largest economy in Africa and the largest pension assets on the continent. Its data infrastructure for institutional investors is among the weakest. South Africa has inflation-linked bonds, a real repo rate published by the SARB, and a mature index ecosystem. Nigeria has a CPI series with a structural break and no official chain-linked alternative.

The gap is not in analytical capacity. There’s no shortage of Nigerian research firms producing excellent work. The gap is infrastructure. Auditable, rules-based benchmarks that any market participant can verify.

Not commentary. Not opinions about what inflation feels like. Published, reproducible numbers.

That is what we built the VNG-CRR to provide. Two inputs. One equation. One index. Updated monthly.

Methodology published. Data downloadable. Every calculation is auditable against source data. All are completely free to the public.

The CPI rebase broke the data. We built the unbroken picture because nobody else did. Whether NBS eventually publishes its own chain-linked series, or the market continues relying on independent providers, says something about where Nigeria’s capital market infrastructure actually stands. We do not think anyone in Abuja is losing sleep over it, but maybe they should be.

E.J. Ibhawoh is the founder and CEO of Venoble Limited, an investment intelligence and capital management firm for African markets. He is a FINRA-qualified capital markets professional with a background spanning investment banking, trading, and software development.

Continue Reading

Feature/OPED

Mr President, Please Reconsider -No to State Police

Published

on

state police nigeria

By Abba Dukawa

Nigeria stands today at a painful and defining crossroads in its security journey. Across the nation, families live with growing fear as insecurity spreads—kidnappings, banditry, and terrorism have become harsh realities in too many communities. These threats do not respect state boundaries. Organised criminal networks move across states, leaving ordinary citizens feeling exposed and abandoned.

Nigerians are facing intertwined challenges. The anger is no longer whispered in private—it is now spoken openly with frustration and worry. Another pressing issue confronting Nigerians is the renewed debate over the creation of state police. When will the federal government strengthen the effectiveness of its security agencies? How much longer must communities endure this uncertainty?

At the same time, another urgent debate rises from the hearts of the people. In the face of this deepening crisis, should state governments be allowed to establish their own police forces to protect their citizens? Or will Nigeria continue to rely solely on a centralised system that many believe is struggling to respond quickly enough to local threats?

These are not just political questions. They are questions of safety, dignity, and the right of every Nigerian to live without fear. The nation is waiting, hoping for bold decisions that will restore trust, strengthen security, and protect the future of its people.  State police cannot be the answer to these pressing issues that bedevil federal security agencies.

Recently, the President appealed to the leadership of the National Assembly to consider constitutional amendments that would create a legal framework for state police, arguing that such reform is necessary to address Nigeria’s worsening security challenges. The fragmented policing structure could complicate efforts to combat crime effectively.

Reigniting the debate over state police comes as no surprise, given that he has long been seen as an advocate for the idea since his tenure as Governor of Lagos State. He supported the concept then and has continued to promote it as President. Many Nigerians, particularly in the South-West, have long called for state police as a means to address the country’s growing insecurity. Despite the constitutional considerations, discussions around state police continue to evoke strong emotions nationwide.

How will state police address security breaches committed by local militias or vigilante groups such as the OPC in the Southwestern states? What actions would state police take regarding the Amotekun group, which is openly endorsed by Southwest governors, if it were to commit serious violations of the rights of citizens, especially those from other parts of the country? How quickly have the proponents of state police chosen to erase from memory the horrific atrocities the OPC inflicted on the Northern community in Lagos in February 2002? The scars of that tragedy are still raw, yet some behave as though it never happened—as if the pain and the lives lost meant nothing. It is a bitter betrayal of justice and our collective conscience.

Reintroducing this issue at a time when the federal security apparatus is already strained shows a lack of sensitivity. Proponents overlook that Section 214(1) clearly states there is only one police force for the federation, the Nigeria Police Force and no other police force may be established for any part of the federation. The section does not permit the establishment of state police. Policing is on the Exclusive Legislative List, meaning only the federal government can create or control a police force.

Even today, the Nigeria Police Force, under the centralised command of the Inspector-General, faces accusations of harassment and intimidation of the weak and vulnerable citizens. If such problems persist under federal control, imagine the risks of placing police authority under state governors, who already wield significant influence over state and local structures.

Implications For The State Police Structures In The Hand Of The State Governors

I must state clearly: I do not support the establishment of state police—at least not at this stage of Nigeria’s development. Our institutions remain fragile, and introducing such a system carries significant risks of abuse. History offers reasons for caution: the Native Authority police of the past were often linked to political repression and misuse of power.

Supporters argue that state police would bring law enforcement closer to local communities and improve response to crime. However, there are serious concerns rooted in Nigeria’s social realities.

Nigeria is a diverse nation with multiple ethnic and religious sentiments. If recruitment into state police forces becomes dominated by particular groups, minority communities may feel marginalised or threatened.

State police could deepen divisions and weaken public trust. State-controlled Police could also become instruments of political intimidation, especially during election periods, potentially targeting opposition figures, critics, and journalists.

Financial capacity is another major concern. Establishing and maintaining a professional police force requires substantial investment in training, equipment, salaries, welfare, and infrastructure. Many states already struggle to pay workers and provide essential services. How, then, can they adequately fund a state police? The likely outcome is poorly trained, under-equipped personnel—conditions that often foster corruption and inefficiency.

Even under federal oversight, Nigeria’s police system struggles with weak accountability and abuse of power. Transferring these weaknesses to the state level without safeguards could have severe consequences.

A poorly structured state police force could become loyal to governors rather than the Constitution, serving political interests rather than citizens’ interests. For these reasons, introducing state police, even with the constitutional amendment, could create more problems than it solves. Sustainability, accountability, and adherence to constitutional principles are critical and will likely be violated

Nigeria must strengthen law enforcement while protecting citizens’ rights and preserving national unity.  Mr President, please reconsider your decision on state police. Nigerians want a strong, effective, and unified police force, not one that risks further dividing a system already struggling to meet its constitutional obligations.

Dukawa can be reached at ab**********@***il.com

Continue Reading

Feature/OPED

Measures at Ensuring Africa’s Food Sovereignty

Published

on

Africa's Food Sovereignty

By Kestér Kenn Klomegâh

China’s investments in Africa have primarily been in the agricultural sector, reinforcing its support for the continent to attain food security for the growing population, estimated currently at 1.5 billion people. With a huge expanse of land and untapped resources, China’s investment in agriculture, focused on increasing local production, has been described as highly appreciable.

Brazil has adopted a similar strategy in its policy with African countries; its investments have concentrated in a number of countries, especially those rich in natural resources. It has significantly contributed to Africa’s economic growth by improving access to affordable machinery, industrial inputs, and adding value to consumer goods. Thus, Africa has to reduce product imports which can be produced locally.

The China and Brazil in African Agriculture Project has just published online a series of studies concerning Chinese and Brazilian support for African agriculture. They appeared in an upcoming issue of World Development.  The six articles focusing on China are available below:

–A New Politics of Development Cooperation? Chinese and Brazilian Engagements in African Agriculture by Ian Scoones, Kojo Amanor, Arilson Favareto and Qi Gubo.

–South-South Cooperation, Agribusiness and African Agricultural Development: Brazil and China in Ghana and Mozambique by Kojo Amanor and Sergio Chichava.

–Chinese State Capitalism? Rethinking the Role of the State and Business in Chinese Development Cooperation in Africa by Jing Gu, Zhang Chuanhong, Alcides Vaz and Langton Mukwereza.

–Chinese Migrants in Africa: Facts and Fictions from the Agri-food Sector in Ethiopia and Ghana by Seth Cook, Jixia Lu, Henry Tugendhat and Dawit Alemu.

–Chinese Agricultural Training Courses for African Officials: Between Power and Partnerships by Henry Tugendhat and Dawit Alemu.

–Science, Technology and the Politics of Knowledge: The Case of China’s Agricultural Technology Demonstration Centres in Africa by Xiuli Xu, Xiaoyun Li, Gubo Qi, Lixia Tang and Langton Mukwereza.

 Strategic partnerships and the way forward: African leaders have to adopt import substitution policies, re-allocate financial resources toward attaining domestic production, and sustain self-sufficiency.

Maximising the impact of resource mobilisation requires collaboration among governments, key external partners, investment promotion agencies, financial institutions, and the private sector. Partnerships must be aligned with national development priorities that can promote value addition, support industrialisation, and deepen regional and continental integration.

Continue Reading

Trending