ATAF Tax Treaty Reforms Advance at 44th CBT Committee

The 44th Cross-Border Taxation (CBT) Technical Committee meeting marked another step in advancing Africa’s collective voice on international tax policy and treaty practice.

Held over two days of intensive technical engagement, the meeting provided a platform to assess global tax developments and refine regional positions on key issues affecting African tax administrations.

Members received updates on developments within the OECD Inclusive Framework, including ongoing technical work under various working parties and recent changes to the Global Minimum Tax rules, as reflected in CBT Technical Note 13. Updates were also provided on progress under the United Nations Convention workstreams, with continued emphasis on ensuring that African perspectives are reflected in emerging global standards.

The Committee also made significant progress in strengthening the ATAF Model Double Taxation Agreement (DTA). Discussions advanced revisions to key provisions, including the treatment of Fees for Services, the introduction of provisions on Automated Digital Services, and further refinements to the taxation of capital.

These updates aim to ensure that the Model DTA remains responsive to the evolving needs and priorities of African countries. The revised provisions will be validated during an international tax workshop scheduled for April 2026.

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