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Prospects for an African continental model multilateral tax agreement for the co-ordination of cross-border corporate tax challenges
Thesis (PhD (International Tax Law))--University of Pretoria, 2023.
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University of Pretoria
2025
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| _version_ | 1867613581607960576 |
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| access_status_str | Open Access |
| author2 | Titus, Afton |
| author_browse | Titus, Afton |
| author_facet | Titus, Afton |
| collection | Thesis |
| dc_rights_str_mv | © 2023 University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria. |
| description | Thesis (PhD (International Tax Law))--University of Pretoria, 2023. |
| format | Thesis |
| id | oai:repository.up.ac.za:2263/100766 |
| institution | University of Pretoria (South Africa) |
| language | English |
| last_indexed | 2026-06-10T12:38:25.653Z |
| license_str | Other — see source repository |
| provenance_str_mv | Harvested via OAI-PMH from UPSpace — University of Pretoria Institutional Repository |
| publishDate | 2025 |
| publishDateRange | 2025 |
| publishDateSort | 2025 |
| publisher | University of Pretoria |
| publisherStr | University of Pretoria |
| record_format | dspace |
| source_str | UPSpace — University of Pretoria Institutional Repository |
| spelling | oai:repository.up.ac.za:2263/100766 Prospects for an African continental model multilateral tax agreement for the co-ordination of cross-border corporate tax challenges Titus, Afton u19388714@tuks.co.za Kekana, Nelson Fehun Aren, Marie-Louise UCTD Sustainable Development Goals (SDGs) International taxation frameworks Tax treaties Continental model multilateral tax agreement African Continental Free Trade Area (AfCFTA) Revenue mobilisation for development Thesis (PhD (International Tax Law))--University of Pretoria, 2023. This study explores the creation of an African Continental Model Multilateral Tax Agreement (MMTA) to address the limitations of current bilateral tax treaties and enhance existing African Regional Economic Community (REC) frameworks for more effective taxation of cross-border business profits. Focusing on critical international taxation framework issues such as taxing rights allocation, Permanent Establishment criteria, and tax dispute resolution, it compares African REC MMTA provisions with those in non-African agreements to identify key weaknesses and propose improvements. The proposed MMTA aims to ensure equitable taxing rights, update nexus rules to capture both physical and digital businesses, and provide robust dispute resolution mechanisms to foster investment. It advocates for harmonized tax policies and tax agreements across African RECs to minimize tax competition, promote intra-African trade, and support regional economic integration under the African Continental Free Trade Area (AfCFTA). By aligning with the Abuja Treaty’s objectives, the framework seeks to enhance revenue mobilization and sustainable economic development in Africa. This research provides a roadmap for creating a tailored multilateral tax treaty that balances diverse regional interests, addressing Africa’s development financing needs while promoting cross-border taxation efficiency. Mercantile Law LLD (International Tax Law) Unrestricted Faculty of Laws SDG-08: Decent work and economic growth SDG-09: Industry, innovation and infrastructure SDG-10: Reduced inequalities SDG-16: Peace, justice and strong institutions SDG-17: Partnerships for the goals 2025-02-12T09:44:29Z 2025-02-12T09:44:29Z 2025 2023-10 Thesis * A2025 http://hdl.handle.net/2263/100766 https://doi.org/10.25403/UPresearchdata.28395305 en © 2023 University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria. application/pdf University of Pretoria |
| spellingShingle | UCTD Sustainable Development Goals (SDGs) International taxation frameworks Tax treaties Continental model multilateral tax agreement African Continental Free Trade Area (AfCFTA) Revenue mobilisation for development Prospects for an African continental model multilateral tax agreement for the co-ordination of cross-border corporate tax challenges |
| title | Prospects for an African continental model multilateral tax agreement for the co-ordination of cross-border corporate tax challenges |
| title_full | Prospects for an African continental model multilateral tax agreement for the co-ordination of cross-border corporate tax challenges |
| title_fullStr | Prospects for an African continental model multilateral tax agreement for the co-ordination of cross-border corporate tax challenges |
| title_full_unstemmed | Prospects for an African continental model multilateral tax agreement for the co-ordination of cross-border corporate tax challenges |
| title_short | Prospects for an African continental model multilateral tax agreement for the co-ordination of cross-border corporate tax challenges |
| title_sort | prospects for an african continental model multilateral tax agreement for the co ordination of cross border corporate tax challenges |
| topic | UCTD Sustainable Development Goals (SDGs) International taxation frameworks Tax treaties Continental model multilateral tax agreement African Continental Free Trade Area (AfCFTA) Revenue mobilisation for development |
| url | http://hdl.handle.net/2263/100766 https://doi.org/10.25403/UPresearchdata.28395305 |