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As 2025 began, African tax authorities ushered in a new wave of reforms, rulings, and regulatory frameworks aimed at strengthening fiscal systems, improving compliance, and setting the tone for the year.
Week 1 (January 1–7, 2025) featured significant developments in Ghana, Nigeria, and South Africa, from international arbitration decisions affecting oil revenue to the enforcement of new tax regulations and the publication of statutory compliance calendars.
This report by Africa Tax Review offers a consolidated view of the major taxation highlights from across the continent.
Africa Tax Review: Key Developments in Week 1 of 2025
1. Ghana: Tullow Oil Secures Relief from $320 Million Tax Claim
In a high-profile ruling delivered by the International Chamber of Commerce (ICC), Tullow Oil was exempted from paying $320 million in Branch Profit Remittance Tax (BPRT) to the Government of Ghana. The dispute arose over Tullow’s earnings from the Deepwater Tano and West Cape Three Points offshore fields.
According to Reuters (Reuters, Jan 2, 2025), the tribunal concluded that Tullow was not liable for BPRT under the terms of the governing agreements. The decision not only provides significant financial reprieve for the oil firm but also sets a legal precedent for future cross-border tax disputes within resource-extractive sectors.
Policy Significance: The ruling spotlights the delicate balance African nations must maintain between attracting foreign investment and preserving tax sovereignty, especially in industries prone to international arbitration.
2. Nigeria: Withholding Tax Regulations 2024 Now in Force
Effective January 1, 2025, Nigeria began enforcing the Withholding Tax (WHT) Regulations 2024, issued by the Federal Ministry of Finance and Coordinating Minister of the Economy. These new rules introduce vital reforms designed to modernize Nigeria’s tax withholding framework.
Key highlights, as reported by KPMG (KPMG Tax News Flash, Oct 2024), include:
- Exemptions for specific transactions, such as:
- Internet data and telephone airtime purchases
- Domestic and international airline tickets.
Standardized WHT remittance and return templates, aimed at enhancing compliance ease and administrative efficiency.
While the official commencement date is January 2025, taxpayers were allowed to adopt the regime as early as July 1, 2024, provided they met stipulated transition requirements.
This reform is part of broader efforts to align WHT mechanisms with economic realities and reduce unnecessary tax burdens for businesses and individuals.
3. South Africa: SARS Releases January 2025 Compliance Calendar
The South African Revenue Service (SARS) began the year by publishing its January 2025 tax calendar, highlighting critical deadlines for tax payments and returns. According to Bloomberg Tax (Bloomberg Tax, Jan 2025), key dates for the month include:
January 7 – Deadline for Pay-As-You-Earn (PAYE) submission and payment.
January 24 – Due date for manual VAT returns and payments.
January 31 – Deadline for Provisional Corporate Income Tax (CIT) and electronic VAT submissions.
This early dissemination of the filing schedule is part of SARS’s strategy to promote voluntary compliance and reduce instances of late filing and penalties through improved taxpayer engagement.
Conclusion
The developments recorded in Week 1 of January 2025 signal a proactive and reform-minded trajectory for tax administrations across Africa.
From Ghana’s international tax arbitration victory to Nigeria’s regulatory overhaul and South Africa’s streamlined compliance procedures, the continent is laying the groundwork for a more efficient and globally integrated tax environment.
As reforms evolve, platforms like www.AfricaTaxReview.com remain pivotal in helping tax professionals, administrators, and policymakers stay informed, analyze trends, and foster a culture of compliance and accountability across Africa.
Olatunji Abdulrazaq CNA, ACTI, ACIArb(UK)
Founder/CEO, Taxmobile.Online
