Can you help shape our future priorities? Take a five minute survey now. Survey closes on 8 July.

Working Paper

ICTD Working Paper 125

Tax Treaty Aggressiveness: Who is Undermining Taxing Rights in Africa?

Published on 26 November 2021

Tax avoidance strategies by multinational companies rely heavily on tax treaties.

Multinational companies can relocate financial activities across countries to ensure the applicability of the most beneficial tax treaties. This ‘treaty shopping’ can be particularly harmful to African countries, impairing their efforts for domestic resource mobilisation and achieving sustainable development goals.

In this paper, we analyse the aggressiveness of tax treaties towards African countries – the extent to which signing tax treaties reduces the taxing rights of African governments. We find that treaties signed with France, Mauritius and the United Arab Emirates reduce withholding tax rates the most, while treaties signed with European countries – and, in particular, the United Kingdom and France – greatly limit other taxing rights, for example, by restricting the scope of permanent establishment definition.

Cite this publication

Millán-Narotzky, L., García-Bernado, J., Diakité, M. and Meinzer, M. (2021) Tax Treaty Aggressiveness: Who is Undermining Taxing Rights in Africa? ICTD Working Paper 125, Brighton: Institute of Development Studies, DOI: 10.19088/ICTD.2021.015

Authors

Lucas Millán-Narotzky

Javier García-Bernado

Maïmouna Diakité

Markus Meinzer

Publication details

published by
ICTD and IDS
journal
ICTD Working Paper 125
doi
10.19088/ICTD.2021.015
isbn
978-1-78118-833-0
language
English

Share

About this publication

Region
Africa

Related content

Opinion

The power of communities during civic space closure in Central America

Rocío Elizabeth Ramírez Argueta, Oficial de programas y proyectos, COMCAVIS TRANS

& 3 others

24 June 2025

Opinion

El poder de las comunidades frente al cierre del espacio cívico en Centroamérica

Rocío Elizabeth Ramírez Argueta, Oficial de programas y proyectos, COMCAVIS TRANS

& 3 others

24 June 2025

Opinion

Shaping the future of AI: The role of non-binding agreements

23 June 2025

Privacy Overview

This website uses cookies so that we can provide you with the best user experience possible. Cookie information is stored in your browser and performs functions such as recognising you when you return to our website and helping our team to understand which sections of the website you find most interesting and useful.