11 Tax-Transparency-In-Africa-2023

Tax Transparency in Africa 2023
Africa Initiative Progress Report

Section head
The Africa Initiative, its members and partners

Given the size of illicit financial flows from African countries, and recognising the potential of tax
transparency and exchange of information to fight them and to raise resources for development,
African countries members of the Global Forum on Transparency and Exchange of Information for
Tax Purposes (Global Forum) decided to create an African-focused programme in 2014: the Africa
Initiative. The objective was to unlock the potential of tax transparency and exchange of information
for Africa by ensuring that African countries are equipped to exploit the improvements in global
transparency to better tackle tax evasion.
Focusing on Africa enables the identification of specific Initially set up for a period of three years (2015-2017), the
approaches and the provision of tailored support to Africa Initiative was renewed for a second phase (2018-
address the specific needs and priorities of African 2020) in November 2017 and for a third phase (2021-2023)
countries to grow their capacity in exchange of in October 2020. The Initiative also agreed on a new
information. The Africa Initiative’s work fits into broader governance framework involving the election of a Chair
agendas, as tax transparency is an opportunity to stem and Vice-Chair to steer its work and a clear set of goals
illicit financial flows and increase domestic resource were agreed upon. Building on the lessons learnt from
mobilisation, which are central to the African Union’s the first year of implementation, the new governance
Agenda 2063 and the Sustainable Development Goals. framework was modified in December 2022, with two
Co-Chairs for a two-year period.
The Africa Initiative is a partnership between the Global
Forum, its African members and several continental, To promote the objectives of the Africa Initiative, the
regional and international organisations and development “Yaoundé Declaration” was signed during a ministerial
partners. With Angola, Sierra Leone and Zimbabwe meeting held on the sidelines of the 2017 Global
recently joining the Global Forum, the Africa Initiative Forum plenary meeting in Yaoundé, Cameroon. The
now counts 37 members and remains open to all African Declaration calls for strengthened efforts to curb
countries.1 It is supported by 16 partners and donors. tax evasion through transparency and exchange of
information (EOI). The Yaoundé Declaration now counts
1. Upon joining the Global Forum, African countries become members of the
33 African countries signatories and the African Union
Africa Initiative. Commission.
2 | TAX TRANSPARENCY IN AFRICA 2023

Section head
11th meeting of
the Africa Initiative,
14-16 June 2022,
Nairobi, Kenya.
The 34 signatories of the Yaoundé Declaration, as of 31 December 2022
Algeria Benin Botswana Burkina Faso Cabo Verde Cameroon Chad Comoros Congo (Rep. of the)
Côte d’Ivoire Djibouti Egypt Eswatini Gabon Ghana Guinea-Bissau Kenya Lesotho
Liberia Madagascar Mali Mauritania Mauritius Morocco Niger Nigeria Rwanda
Senegal Seychelles South Africa Togo Tunisia Uganda African Union Commission
More information on the Yaoundé Declaration is the Common Reporting Standard (CRS). The Initiative’s
available at https://www.oecd.org/tax/transparency/ current work programme is based on a three-year
what-we-do/technical-assistance/the-yaounde- mandate, which covers the period 2021-2023. The Africa
declaration.htm. Initiative builds on the progress achieved by members
since 2014 and continues to raise political awareness
WORK PROGRAMME OF THE AFRICA INITIATIVE and support new members to implement the “core
stage” of tax transparency and EOI, with an emphasis
At the onset, the Africa Initiative agreed on an ambitious on beneficial ownership information transparency.
work programme to develop and consolidate a culture The Africa Initiative has also identified “enhanced
of transparency and EOI in African countries, and to building blocks” that can be implemented by interested
progress towards the implementation of automatic members.
exchange of financial account information (AEOI) under
TAX TRANSPARENCY IN AFRICA 2023 | 3

Overview
The “core stage” encompasses: l increase in the number of African countries

l set up of operational EOI units with adequate implementing AEOI on a practical timeframe and
resources, including delegated competent authority benefitting from technical support including on
powers and an EOI internal procedure or manual confidentiality and data safeguard
l define a clear strategy to use EOI as a tool to improve l measure the impact and benefit of EOI through periodic
tax audits, sensitisation of relevant stakeholders and collection and tracking of statistical information.
actively increasing the number of requests made to
treaty partners The “enhanced building blocks” are areas identified
as interesting for capacity building and collaborative
l expand the network of EOI relationships by joining activities. These include cross-border assistance in the
the Convention on Mutual Administrative Assistance recovery of tax claims, the effective use of CRS data and
in Tax Matters the use of EOI data for non-tax purposes.
l receive a satisfactory rating in the second round of Members of the Africa Initiative meet twice a year
transparency and exchange of information on request to take stock of their progress and discuss ways of
peer review addressing their remaining challenges.
Members of the Africa Initiative
Algeria Angola Benin Botswana Burkina Faso Cabo Verde Cameroon Chad
Congo (Rep. of the) Côte d’Ivoire Djibouti Egypt Eswatini Gabon Ghana Guinea
Kenya Lesotho Liberia Madagascar Mali Mauritania Mauritius Morocco
Namibia Niger Nigeria Rwanda Senegal Seychelles Sierra Leone South Africa
Tanzania Togo Tunisia Uganda Zimbabwe
More information on the Africa Initiative is available at: https://oe.cd/africa-initiative.

Overview
Leadership of the Africa Initiative since 2021
2021-2022 2023-2024
CHAIR VICE-CHAIR CO-CHAIR CO-CHAIR

Mr Githii Mr Edward Dr Philippe Kokou Mr Edward
Mburu Kieswetter Tchodie Kieswetter
Kenya South Africa Togo South Africa
Commissioner General, Commissioner, South African Commissioner General, Commissioner, South African
Kenya Revenue Authority Revenue Service Togolese Revenue Office Revenue Service
Partners and donors of the Africa Initiative
Schweizerische Eidgenossenschaft
Confédération suisse
Confederazione Svizzera
Confederaziun svizra
Swiss Confederation
Federal Department of Economic Affairs,

Education and Research EAER
AFRICAN DEVELOPMENT BANK GROUP State Secretariat for Economic Affairs SECO
African Development Commonwealth Association International Finance
GROUPE DE LA BANQUE AFRICAINE
Bank Group
DE DÉVELOPPEMENT of Tax Administrators Corporation (World Bank Group) Switzerland
African Tax Co-funded by the

Administration Forum European Union
European Union Netherlands United Kingdom
African Union West African Tax

Commission France Norway Administration Forum
Cercle de réflexion
et d’échange des dirigeants
des administrations fiscales Germany Senegal* World Bank Group
* Contribution of the Resource Mobilisation and Investment Attractiveness Institutional Support (PAIMRAI) Project piloted by the Ministry of Finance and Budget of Senegal
and supported by the African Development Bank.

Tax Transparency in Africa
Foreword
Domestic resource mobilisation (DRM) is at the fore of the development
agenda in Africa. With this in mind, the African Union Commission
(AU Commission) supports initiatives that strive to reduce Africa’s
dependency to external sources of revenue and sustain DRM on the
continent. This includes the fight against all forms of illicit financial
flows (IFFs) that deprive African nations of the much-needed resources
for their development.

Foreword
The Africa Initiative is a concrete and impactful

contribution to tackle tax evasion and other forms of
IFFs through tax transparency. Looking at the results
Looking at the results achieved in a few years,
achieved in a few years, in particular in terms of DRM, in particular in terms of domestic resource
the AU Commission welcomes the level of commitment mobilisation, the AU Commission welcomes
and engagement of African countries. With the support
of the Global Forum on Transparency and Exchange of the level of commitment and engagement of
Information for Tax Purposes (Global Forum) and other African countries.
partners, African countries are implementing stronger
tax transparency frameworks and advancing the use
of exchange of information (EOI). Challenges remain, start automatic exchange of financial account
and many African countries are at the beginning of information (AEOI) by a specific date. The more African
their tax transparency journey and are yet to translate countries make use of cross-border EOI for tax purposes,
EOI into revenues. This requires the Africa Initiative the greater the impact will be on tax revenues.
to ensure that African countries are also engaged and Four African countries were able to identify additional
are benefiting from the global move towards better revenues totalling EUR 76.6 million in 2022, the highest
transparency in tax matters. To achieve this, the Africa annual amount reported since the establishment of the
Initiative needs to be sufficiently equipped to help Africa Initiative in 2014. This includes EUR 10.6 million
African countries to benefit from the progress made in additional revenue from the use of financial account
globally over the past decade in enhancing DRM through information received by one of the five African countries
improved tax transparency and EOI. currently engaged in AEOI. Although a lot of progress is
still needed, we can already see that EOI is one of the
The AU Commission will therefore continue to strongly solutions to address the issues of IFFs in Africa, and
support the Africa Initiative and work with the Global an effective tool to increase domestic resources on the
Forum and other partners to enhance tax transparency continent.
on the continent. The annual publication Tax Transparency
in Africa: the Africa Initiative Progress Report plays a unique On behalf of the AU Commission, I would like to thank
role as it helps us take stock of the progress made and all parties involved in the publication of this report. I
strive to address the remaining challenges faced by invite all African countries to join the Africa Initiative
African countries. Thanks to the contribution of 38 African and encourage current members to continue their
countries that have provided answers to the survey, the efforts, as the stories of their peers and the experiences
2023 report is a unique and valuable work by its scope shared are the best demonstration of the usefulness and
and its in-depth analysis. It shows continuing progress. the impact of tax transparency for DRM.
One new member joined the Africa Initiative in The African community should use this report as a
2022, bringing the total number of African countries source of information that can help them reflect and act
participating in the global tax transparency work to 34 together and with our partners to ensure that “Africa
as at December 2022. Since then, the Africa Initiative takes full responsibility for financing her development”
has welcomed three new African countries, bringing the as espoused in our Agenda 2063.
current membership to 37.
Albert M. Muchanga
The number of African countries making use of Commissioner for Economic Development, Trade,
exchange of information on request has increased, Tourism, Industry, and Minerals
as well as the number of countries committed to African Union Commission

Preface
Tax Transparency in Africa 2023: Africa Initiative Progress Report (TTiA 2023) is the fifth edition of this annual
report, which takes stock of the progress made by African countries in tackling tax evasion and other illicit
financial flows (IFFs) through enhanced tax transparency and exchange of information (EOI). The report is
a joint publication by the African Union Commission, the African Tax Administration Forum and the Global
Forum on Transparency and Exchange of Information for Tax Purposes (Global Forum). It is a key output
of the Africa Initiative launched nine years ago by the Global Forum, its African members, partners and
donors, to unlock the potential of EOI for African countries.

Preface
TTiA 2023 is published as African countries are African countries are implementing the AEOI standard
recovering from the effects of the COVID-19 pandemic and committing to first exchanges by a specific date,
and being confronted with new challenges, such as and ten of them are committed to starting automatic
disruptions to global supply chains due to conflicts and exchanges by a specified date.
unreliable weather. As EOI is now well established as
an effective tool to tackle tax evasion and other IFFs, it The progress is a result of both the growing political
can play a critical role in enhancing African countries’ buy-in for the tax transparency agenda and the
domestic resource mobilisation (DRM) efforts to raise enhanced capacity-building led by a coalition of donors
much needed revenues. and partners working together under the banner of
Africa Initiative.
Thirty-eight African countries have provided inputs to
this report. As in previous editions, the report provides We take this opportunity to thank all the members,
statistical information on the implementation of the tax partners and donors of the Africa Initiative for their
transparency standards – Standard on Transparency and contribution to advancing the tax transparency agenda
Exchange of Information on Request (EOIR standard) in Africa. We remain steadfast in our commitment
and the Standard on Automatic Exchange of Financial to help African countries address the challenges the
Account Information (AEOI standard) – and their continent faces in implementing and benefitting from
contribution to DRM in Africa. the tax transparency standards. For together, we can
achieve more.
TTiA 2023 shows significant progress. More African
countries are joining global efforts to combat tax
evasion through tax transparency. They are also making
use of the infrastructures to help the resolution of tax As EOI is now well established as an effective
audits/investigations with a cross-border element and to
tool to tackle tax evasion and other IFFs, it
detect and deter cross-border tax evasion. In 2022, four
African countries identified EUR 66 million in additional can play a critical role in enhancing African
taxes through EOIR, while one of the five African countries’ domestic resource mobilisation
countries engaged in AEOI reported the identification of
over EUR 10 million in additional revenues thanks to the
efforts to raise much needed revenues.
use of the data automatically received. More and more
Edward Kieswetter Dr Philippe Kokou Tchodie Zayda Manatta Logan Wort

Co-Chair of the Co-Chair of the Head of the Secretariat Executive Secretary
Africa Initiative Africa Initiative Global Forum on African Tax
Commissioner, South Commissioner General, Transparency and Administration Forum
African Revenue Service Togolese Revenue Office Exchange of Information
for Tax Purposes

Section head
Acknowledgements
The fifth edition of Tax Transparency in Africa is jointly Corporation, the West African Tax Administration Forum
published by the African Union Commission, the African and the World Bank for promoting the tax transparency
Tax Administration Forum and the Global Forum on agenda in Africa.
Transparency and Exchange of Information for Tax
Purposes (Global Forum). Prepared by the Global Forum The Global Forum Secretariat is also immensely grateful
Secretariat,1 the Tax Transparency in Africa 2023 report to the donors who contribute to the funding of the Africa
presents the progress of the Africa Initiative – in which Initiative and the Global Forum’s capacity building to
all African members of the Global Forum and some African countries on tax transparency and exchange
non-member African countries participate – for the year of information. These include the European Union,
2022. France, Germany, the Netherlands, Norway, Senegal,5
Switzerland and the United Kingdom.
The Global Forum Secretariat would like to acknowledge
with much appreciation the African Tax Administration Finally, the authors extend special thanks to officials
Forum,2 the Department for Economic Development, from the ministries of finance and tax administrations
Trade, Industry and Mining of the African Union of all the 38 African countries, including non-members
Commission3 and the Governance and Economic Reform of the Global Forum, who provided data by responding
Department of the African Development Bank Group4 to the Africa Initiative questionnaire. These data
for their contributions to this report. The Global Forum and responses were analysed and form the basis for
Secretariat also thanks its other partners: the Cercle de the insights presented in the report. Their efforts in
Réflexion et d’Échange des Dirigeants des Administrations gathering the data and their patience in providing
Fiscales, the Commonwealth Association of Tax further clarifications have been critical to the quality of
Administrators, the International Finance this report.6
1. This report was prepared by the following staff of the Global Forum Secretariat: Irene Bashabe, Clement Migai, Lena Walder – a team led by Ervice Tchouata and under the
supervision of Hakim Hamadi, Head of the Capacity-Building and Outreach Unit, and Zayda Manatta, Head of the Global Forum Secretariat.
2. In particular, the authors would like to thank Mary Baine, Thulani Shongwe, Ephraim Murenzi under the leadership of Logan Wort, Executive Director, ATAF.
3 Ndinaye Sekwi Charumbira and Rumbidzai Treddah Manhando under the supervision of Djamel Ghrib, Director of Economic Development Integration & Trade.
4. Evelynne Change and Sandrine Ebakisse, under the supervision of Abdoulaye Coulibaly, Director of the Governance and Economic Reform Department.
5. Contribution of the Resource Mobilisation and Investment Attractiveness Institutional Support (PAIMRAI) Project piloted by the Ministry of Finance and Budget of Senegal
and supported by the African Development Bank.
6. In addition to the 38 African countries that provided data, the authors would particularly like to thank the following for their specific contributions: Kenya Revenue
Authority, Liberia (Felicia Powson), Direction Générale des Impôts de Madagascar, Direction Générale des Impôts du Mali, Mauritius Revenue Authority, Rwanda (Jackson
Rugambwa, Jean Clement Gatera and Frivole Niyomufasha), the South African Revenue Service and Uganda Revenue Authority.

Contents
Contents
The Africa Initiative, its members and partners 2 3. AFRICAN COUNTRIES’ PROGRESS
Foreword 6 IN IMPLEMENTING THE TAX TRANSPARENCY
Preface 8 STANDARDS 40
Acknowledgements 10
Strengthening infrastructures for exchange
Abbreviations and acronyms 12
of information on the continent 42
Executive summary 13
Implementation of the standard for exchange
Tax transparency in Africa at a glance 16
of information on request 49
Implementation of the standard of automatic
1. THE CRITICAL ROLE OF TAX TRANSPARENCY IN
exchange of financial account information 55
FIGHTING ILLICIT FINANCIAL FLOWS IN AFRICA 18
Illicit financial flows and their consequences 19 4. USING TAX TRANSPARENCY FOR DOMESTIC
International tax transparency standards as a tool to RESOURCE MOBILISATION 61
curb illicit financial flows 20
Use of exchange of information on request by African
The impact of exchange of information on request 20
countries 62
The impact of automatic exchange of financial account
Use of automatic exchange of information by African
information 22
countries 66
2. DEVELOPMENTS IN TAX TRANSPARENCY

5. LOOKING AHEAD 68
IN AFRICA IN 2022 24
Making a radical change in the use of the exchange
Building strong political buy-in to unpack the benefits
of information on request 69
of tax transparency for all African countries 26
Unpacking the benefit of automatic exchange
Capacity building in 2022 28
of financial account information for more African
Cross-border assistance in the recovery of tax claims 35
countries 69
African countries’ active contributions to Global Forum
Strengthening African tax authorities’ capacities
work and capacity-building activities 35
to benefit from tax transparency and exchange
Partnerships to support African countries 36
of information 69
Advancing the use of cross-border assistance
in the recovery of tax claims 69
ANNEX
Summary of the tax transparency progress by country

in 2022 70
Please cite this report as:

OECD (2023), Tax Transparency in Africa 2023: Africa Initiative Progress Report, Global Forum on Transparency and Exchange of Information for Tax
Purposes, OECD, Paris, https://www.oecd.org/tax/transparency/documents/tax-transparency-in-africa-2023.pdf.

Abbreviations and acronyms

AEOI Automatic Exchange of Financial Account Information
AfCFTA African Continental Free Trade Area
AfDB African Development Bank
AML Anti-Money Laundering
ATAF African Tax Administration Forum
AU African Union
CA Competent Authority
CBO Unit Capacity Building and Outreach Unit of the Global Forum Secretariat
CRS Common Reporting Standard
CREDAF Cercle de Réflexion et d'Échange des Dirigeants des Administrations fiscales
DRM Domestic Resource Mobilisation
DTC Double taxation convention
EAC East African Community
ECOWAS Economic Community of West African States
EOI Exchange of information
EOIR Exchange of Information on Request
EU European Union
Global Forum Global Forum on Transparency and Exchange of Information for Tax Purposes
IFC International Finance Corporation
IFF Illicit Financial Flows
ISM Information Security Management
MAAC Convention on Mutual Administrative Assistance in Tax Matters
OECD Organisation for Economic Co-operation and Development
TIEA Tax information exchange agreement
ToR Terms of reference
TTiA Tax Transparency in Africa
UNCTAD United Nations Trade and Development Conference
VDP Voluntary Disclosure Programme
WAEMU West Africa Economic and Monetary Union
WATAF West African Tax Administration Forum
WB World Bank

Section head
Executive summary
Tax Transparency in Africa 2023: Africa Initiative Progress Report (TTiA)
includes information provided by 38 African countries, the joint-
highest number since the first edition of the report in 2019.* It shows
remarkable developments in 2022 on the two strategic axes of the
Africa Initiative: (i) raising political awareness and commitment
in Africa and (ii) developing capacities in African countries in tax
transparency and exchange of information (EOI).
In 2022, the Africa Initiative redoubled its efforts to drum up political

buy-in for tax transparency and EOI on the African continent at
continental and regional level, through engagements with the
African Union (AU) Commission, African Union member states, the
African Development Bank, the African Tax Administration Forum and
the West African Tax Administration Forum. Engagements were
also held with other partners such as the Cercle de réflexion
et d’échange des dirigeants des administrations fiscales.
* Algeria, Angola, Benin, Botswana, Burkina Faso, Cabo Verde, Cameroon, Côte d’Ivoire, Djibouti,
Egypt, Eswatini, Gabon, Gambia, Ghana, Guinea Bissau, Kenya, Lesotho, Liberia, Madagascar, Mali,
Mauritania, Mauritius, Morocco, Namibia, Niger, Nigeria, Rwanda, Senegal, Seychelles, Sierra Leone,
South Africa, Sudan, Tanzania, Togo, Tunisia, Uganda, Zambia and Zimbabwe.
TAX
TAXTRANSPARENCY
TRANSPARENCYIN
INAFRICA 2023 | 13
AFRICA 2023
Executive summary
The high-level engagements contributed to

strengthening collaboration with key international and The work on raising political awareness and
regional institutions to promote the tax transparency
agenda in Africa. The International Finance commitment in Africa culminated in the
Corporation and the Commonwealth Association of Tax Republic of the Congo joining the Global
Administrators were welcomed as partners of the Africa
Forum and the Africa Initiative in June 2022.
Initiative.
In addition, Botswana endorsed the Yaoundé
The work on raising political awareness and Declaration in March 2022 as 34th signatory.
commitment in Africa culminated in the Republic of
the Congo joining the Global Forum and the Africa
Initiative in June 2022. In addition, Botswana endorsed The year 2022 also confirms the return on investment in
the Yaoundé Declaration in March 2022 as 34th signatory EOI infrastructures is assured when countries actively
(33 African countries and the AU Commission). make use of it. In 2022, African countries reported
EUR 66 million in additional revenues (tax, interest and
In 2022, Tunisia committed to start automatic exchanges penalties) as a result of EOI requests sent, a 77% increase
of financial accounts information (AEOI) by 2024, joining on the EUR 37.2 million reported in 2021. In addition,
four other African countries (Kenya, Morocco, Rwanda one African country identified over EUR 10 million in
and Uganda) that are committed to undertake their additional revenue from the data received automatically,
first automatic exchanges by a specific date, and five underlining the potential of AEOI to African countries. In
other countries already exchanging on a reciprocal basis total, five African countries identified additional revenues
(Ghana, Mauritius, Nigeria, Seychelles and South Africa). totalling EUR 76.6 million, the highest amount since the
establishment of the Africa Initiative in 2014. This brings
African countries continued to improve their the total revenue gains from EOI in Africa since 2009 at
EOI infrastructures in 2022. Angola was invited to sign over EUR 1.69 billion, through offshore tax investigations
the Convention on Mutual Administrative Assistance including EOIR, voluntary disclosure programmes
in Tax Matters. Madagascar signed the Convention, and launched in the context of the implementation of
Burkina Faso, Mauritania and Rwanda deposited their AEOI and making effective use of the data received
instruments of ratification. As of December 2022, 94% automatically.
of 38 African countries that participated in the survey
had delegated the Competent Authority powers and Finally, in response to the call by the Africa Initiative
functions to the tax administration, while 76% had in 2021 for members to take deliberate steps to put in
established EOI units. Further, 62% had documented place the essential building blocks for enhancing the use
formal procedures for handling EOI requests and of cross-border assistance in the recovery of tax claims,
57% had put in place tracking systems to monitor the a workshop was held in 2022 to help participating
handling of EOI requests and improve the effectiveness countries with tools for assessing the maturity of their
of the EOI function. domestic tax debt management functions. Additionally,
the training activities on cross-border assistance in the
In addition, African countries continued to put recovery of tax claims were launched in Africa with a
established EOI infrastructures to good use. Although first in-country training held for Tunisia.
they cumulatively received more requests than they sent
in 2022, the number of countries sending requests rose While this report demonstrates African countries’
to 19, up from 15 in 2021. Moreover, the gap between progress in using tax transparency and EOI, it remains
the number of requests sent and received remained uneven. A significant number of African countries are
narrower than pre-2020 levels. However, as seen in 2021, not yet effectively using available EOI infrastructures to
a small cluster of countries account for the bulk of enhance their efforts for domestic resource mobilisation.
EOI activity in Africa: four countries account for 86% of This calls for new strategies by African tax authorities to
all requests sent, with two countries alone accounting establish a culture of EOI and ensure that it becomes a
for over 75%. tool to promote tax compliance. These strategies should

Executive summary
11th meeting of
14-16 June 2022,
Nairobi, Kenya.
include continued capacity-building and awareness- received pre-membership support to implement an

raising activities targeting tax auditors/investigators agenda for tax transparency within their countries.
on the usage of EOI as a tool to complement domestic Fifteen training events were organised in 2022 and
information. delivered to 1 170 officials representing 34 members of
the Africa Initiative and 3 non-members. Further, more
Progress is unbalanced between members of the Global than 1 800 additional officials were trained by EOI local
Forum/Africa Initiative and between members and trainers who participated in the “Train the Trainer”
non-members. In general, older members have well- programme. Finally, eight African female tax
established EOI infrastructures compared to newer professionals participated in the “Women Leaders in Tax
members, and similarly for members compared to Transparency” programme aimed at promoting female
non-members. These discrepancies call for continued leadership in tax transparency.
engagements at the continental, regional and domestic
levels to get political buy-in for tax transparency and Looking ahead, the Africa Initiative will continue
EOI to ensure that tax authorities participate in and to advocate for African countries to make effective
benefit from tax transparency and EOI work. use of EOI by sending more requests and exploiting
information received in their tax audits, as well as
Technical assistance was provided to 33 African making effective use of data received automatically.
countries to overcome these challenges: 15 countries Political dialogue will be sustained at the continental,
received comprehensive support and another 14 regional and country levels to champion support for tax
benefitted from tailored technical assistance to transparency and EOI as a crucial tool for combating
address specific needs. AEOI implementation was also tax evasion and reducing IFFs from Africa. The Africa
given specific attention, with nine countries receiving Initiative will also continue developing new tools and
“à la carte” technical assistance to establish the essential building capacity on cross-border assistance in the
EOI building blocks. In addition, four non-members recovery of tax claims.

Tax transparency in Africa at a glance
The Africa Initiative has developed and expanded its capacity- Donors: European Union, France, Germany,
building activities to ensure transparency and exchange the Netherlands, Norway, Senegal*, Switzerland,
of information (EOI) benefit African countries. In 2022, five United Kingdom.
African countries reported identifying EUR 76.6 million of
additional revenues (tax, interests and penalties) through EOI, Africa in the Global Forum
the highest amount since the launch of the Africa Initiative in l 20 African countries have joined the Global Forum
2014. These latest figures bring the total revenues identified since 2014.
by African countries as a result of EOIR, other offshore tax l 37 African countries are members of the Global Forum,
investigations, AEOI-related voluntary disclosure programmes they make up 22% of its membership.
and the use of data automatically exchanged to at least EUR l AU Commission, ATAF, AfDB and WATAF are observers.
1.69 billion since 2009. .
37 Members of the Africa initiative Capacity building in figures in Africa in 2022

Algeria, Angola, Benin, Botswana, Burkina Faso, Cabo Verde, l The induction programme for 15 countries were advanced.
Cameroon, Chad, Congo (Rep. of the), Côte d’Ivoire, Djibouti, l 14 members received tailored support.
Egypt, Eswatini, Gabon, Ghana, Guinea, Kenya, Lesotho, Liberia, l 4 non-members received pre-membership support.
Madagascar, Mali, Mauritania, Mauritius, Morocco, Namibia, l 15 training events were held with the participation of
Niger, Nigeria, Rwanda, Senegal, Seychelles, Sierra Leone, 1 170 officials from 34 members and 3 non-members.
South Africa, Tanzania, Togo, Tunisia, Uganda and Zimbabwe. l 27 officials from 13 African countries participated in the
2022 edition of the Train the Trainer Programme and held
Donors and partners of the Africa initiative 21 local trainings for 433 tax officials in their respective
Partners: African Development Bank Group (AfDB), African countries.
Tax Administration Forum (ATAF), African Union (AU) l 8 female officials from 8 African members participated in
Commission, Cercle de Réflexion et d’Échange des Dirigeants the first edition of the Women Leaders in Tax Transparency
des Administrations Fiscales (CREDAF), Commonwealth programme.
Association of Tax Administrators (CATA), International l 9 African members joined the Global Forum’s Information
Finance Corporation (IFC), West African Tax Administration Security Management network.
Forum (WATAF) and World Bank.
Implementation of exchange of information in Africa in 2022

Most African members have set up the core elements for effective EOI. .
Work is ongoing with the recent members to fill the gap.
Share of countries giving low, medium and high priority to EOI
Competent
EOl unit
authority
in place
delegation
30
37 (79%)
(97%) In place
Not in place
EOl
EOl * C
ontribution of the Resource
tracking
manual Mobilisation and Investment
tool 23
(61%) Attractiveness Institutional Support
25 (PAIMRAI) Project piloted by the
(66%) Ministry of Finance and Budget
of Senegal and supported by the
African Development Bank.

Expanding exchange of information relationships Implementation of
Africa’s EOI network has reached over 3 070 EOI relationships (agreements in force), of which 80% are EOI automatic exchange
relationships created under the Convention on Mutual Administrative Assistance in Tax Matters (MAAC). of financial account
information in Africa
Number of exchange of information relationships in force established by African countries since 2014
3 500 20 2017 Seychelles
EOI relationships created under the MAAC EOI relationships without the MAAC 18 South Africa
African countries with the MAAC in force 18
3 000
2018 Mauritius
Number of countries with the MAAC in force

16
629 16
(20%)
Seychelles
2 500 618 14
Number of EOI relationships
(23%) South Africa

12
12
2 000 2019 Ghana
10
9 9 9
484
(24%) 10 Mauritius
1 500 474 Seychelles
7 (29%) 8
461
469 2 448
(80%)
South Africa
(33%) 2 112
1 000 409 (34%) (77%) 6
(34%)
1 500 2020 Ghana
392 4
3 (44%)
972
1 180
(71%)
(76%)
Mauritius
500 882
360
(69%) 490
792
(66%) (66%) (67%)
2 Nigeria
168
(31%)
(56%)
Seychelles
0 0
2014 2015 2016 2017 2018 2019 2020 2021 2022 South Africa
2023 Ghana
(Expected) Mauritius
Requests for information sent and received by African countries in 2022 Nigeria
African countries made a total of 531 EOI requests in 2022. Although this represents a decline from the Seychelles
592 requests sent in 2021, the gap between requests sent and received is narrower than pre-2020 levels. South Africa
While the number of requests sent dropped, the number of incoming EOI requests rose 9% to 683 in Uganda
2022, from 628 in 2021. Most African countries are still behind their potential and more efforts need to 2024 Ghana
be put into the operationalisation of EOI. (Expected) Kenya
Mauritius
Requests for information sent and received by African countries since 2014 Nigeria
800 Seychelles
Total number of EOI requests received Total number of EOI requests sent South Africa
683
700 Tunisia
628
600
609
585 Uganda
569
592 531
Number of EOI requests
502
2025 Ghana
500 469
421
(Expected) Kenya
451
400 Mauritius
381 Morocco
300 Nigeria
279
200
198 Rwanda
218
109
Seychelles
100 South Africa
38 67 Tunisia
0
2014 2015 2016 2017 2018 2019 2020 2021 2022 Uganda
Revenue identified in 2022 Total since 2009

1 800
African countries reported EUR 66 million in additional taxes as a result of EOI requests sent in 2022, a 47% 1 692
1 600
increase on the EUR 37.2 million reported in 2021. In addition, one African country identified EUR 10.6
Total since 2009
million in additional revenue using CRS data. In total, five African countries reported identifying at least EUR 11800
400
76.6 million, the highest figure since the launch of the Africa Initiative in 2014. This brings the total revenue 1 200 1746
692
gains from EOI in Africa since 2009 at over EUR 1.69 billion, through offshore tax investigations including 1 600
1 000
EOIR, voluntary disclosure programmes (VDPs) launched in the context of the implementation of AEOI and
1 400
making effective use of the data received automatically. 800 746
1 200
600
Yearly EOI revenues identified by African countries (in EUR million)
945
400
1 000
200
800
6.2 0
23.5 30.2 67.0 20.0 14.5 35.1 37.2 76.6 600
EOIR and other offshore
investigations
945
400
AEOI
2014 2015 2016 2017 2018 2019 2020 2021 2022 (VDPs and use of CRS)
200
0
TAX TRANSPARENCY
EOIRINand
AFRICA
other 2023 | 17
offshore
investigations
AEOI
(VDPs and use of CRS)
Section head
The critical role of

tax transparency in
fighting illicit financial
flows in Africa
1 The international tax transparency standards
have proven to be an effective tool in curbing tax evasion
and other illicit financial flows and generating additional
revenue ready to be invested in the development and
provision of public services. As a matter of fact, it is
already, and should be even more in the future, beneficial
to all Global Forum members in their diversity. During
the past eight years, the Africa Initiative has changed
the tax transparency landscape in Africa, acting jointly
with the Global Forum. However, continuous action is
needed to ensure a long-lasting positive impact. Working
with its partners, the Global Forum will continue to serve
African countries and to support the Africa initiative in its
efforts to build or enhance their capacities to use the EOI
standards at their full potential on the continent.
Gaël Perraud, Chair of the Global Forum
18 | TAX TRANSPARENCY
TRANSPARENCYININAFRICA
AFRICA2023
2023
The critical role of tax transparency in fighting illicit financial flows in Africa
Tax transparency is fundamental to the sustainable It is generally accepted that IFFs most
development of a country and its government’s capacity
certainly surpass aid flows and investment in
to respond to its people’s needs. In the absence of
transparency, tax systems are exposed to tax evasion,
volume in Africa.
which undermines the collection of tax revenues and
affects their fairness. Beyond tax evasion, the lack The 2020 estimate by the UNCTAD is even higher, set at
of transparency also enables other forms of illicit USD 88.6 billion (EUR 85.1 billion) annually,5 or 3.7% of
financial flows (IFFs), which have a negative impact on Africa’s gross domestic product.
development. IFFs do not only impede a country’s ability
to finance essential public services, such as health care In parallel, the annual Sustainable Development
and education, but has also a detrimental effect on Goals financing gap for Africa was estimated at
its economic potential. The negative impact of IFFs is USD 200 billion (EUR 192 billion) pre COVID-19 pandemic.
especially adverse for developing countries, considering The repercussions of the pandemic, however, created
their limited resources. an additional financing need of around USD 154 billion
(EUR 148 billion), which means the resources necessary
ILLICIT FINANCIAL FLOWS AND THEIR to fill the Sustainable Development Goals financing gap
CONSEQUENCES increased by over 50%.6 This emphasises once more the
urgency of eliminating IFFs to capture much-needed
While there is no universally accepted definition of IFFs, resources to meet the goals of the 2030 Agenda for
it is widely agreed that they are “generated by methods, Sustainable Development (Target 16.4 of Goal 16): “By
practices and crimes aiming to transfer financial capital out 2030, significantly reduce illicit financial and arms flows,
of a country in contravention of national or international strengthen the recovery and return of stolen assets and combat
laws”.1 This includes money laundering, bribery and tax all forms of organised crime”.7
evasion.
While almost every country faces IFFs, the consequences
Several studies have tried to estimate the total amount for developing countries are particularly damaging,
of IFFs in Africa. However, due to the secret nature of IFFs given their limited resources. It prevents countries from
and the absence of a universally accepted definition, it is financing much-needed public services, hampering
extremely difficult to accurately track them, and estimates economic and social development. One of the immediate
can vary considerably.2 Yet, it is generally accepted that consequences of tax evasion is that it hampers domestic
IFFs most certainly surpass aid flows and investment in expenditure and investment and translates into fragile
volume in Africa.3 In 2019, the AU Commission estimated infrastructure, insufficient and low-quality education,
that the amount of IFFs from Africa ranged between as well as a lack of public safety provision through
USD 50 and USD 80 billion (EUR 48-77 billion) annually.4 adequate police force.8 IFFs hence represent a major
1. OECD (2014), Illicit Financial Flows from Developing Countries: Measuring OECD Responses, OECD Publishing, Paris, http://dx.doi.org/10.1787/9789264203501-en. For more
discussions on the definition of IFFs and the critical role of EOI in combating tax evasion as a component of IFFs see the 2021 and 2020 Tax Transparency in Africa Reports
available at https://www.oecd.org/tax/transparency/what-we-do/technical-assistance/africa-initiative.htm.
2. United Nations. Economic Commission for Africa (2015), Track it! Stop it! Get it! Illicit financial flows: Report of the High Level Panel on Illicit Financial Flows from Africa, Addis
Ababa, https://www.unodc.org/documents/NGO/AU_ECA_Illicit_ Financial_Flows_report_EN.pdf.
3. See for example OECD (2014), Illicit Financial Flows from Developing Countries: Measuring OECD Responses, op. cit.; United Nations Economic Commission for Africa (2015),
Track it! Stop it! Get it! Illicit financial flows: Report of the High Level Panel on Illicit Financial Flows from Africa, op. cit.; African Union Commission (2019), Domestic Resource
Mobilization: Fighting against Corruption and Illicit Financial Flows, AUC Publishing, Addis Ababa; and UNCTAD (2020), Economic Development in Africa Report 2020: Tackling
Illicit Financial Flows for Sustainable Development in Africa, United Nations, Geneva.
4. African Union (AU) Commission (2019), Domestic Resource Mobilization: Fighting against Corruption and Illicit Financial Flows, op. cit.
5. UNCTAD (2020), Economic Development in Africa Report 2020, Tackling Illicit Financial Flows for Sustainable Development in Africa, op. cit.
6. UNCTAD (2022), Report on Illicit Financial Flows in Africa. https://unctad.org/system/files/non-official-document/IFFsAfrica_FinalReport_20221121.pdf.
7. UN (2015), Transforming our world: the 2030 Agenda for Sustainable Development, Resolution adopted by the General Assembly on 25 September 2015, https://documents-
dds-ny.un.org/doc/UNDOC/GEN/N15/291/89/PDF/N1529189.pdf?OpenElement.
8. OECD (2014), Illicit Financial Flows from Developing Countries: Measuring OECD Responses, op. cit.

obstacle to international development efforts and Transparency and Exchange of Information on

exacerbate countries’ fragility in the long-term. Ensuring Request (EOIR) and the Standard on Automatic
tax transparency is one of the solutions to untie the Exchange of Financial Account Information (AEOI)
Gordian Knot of IFFs and mobilise more domestic under the Common Reporting Standard (CRS) listed in
resources for development.9 Table 1, aim at improving transparency by disclosing
legal and beneficial ownership information, as well as
Likewise, the Addis Ababa Action Agenda, aiming to align accounting and banking information. These standards
all financial flows and policies with the 2030 Agenda also seek to improve the access to that information
for Sustainable Development priorities, highlights the and its effective exchange with foreign partners.
importance of stemming IFFs.10 The African Union (AU) By promoting the adoption and implementation of
Agenda 2063 also outlines Africa’s commitment to legal and administrative frameworks that ensure the
accelerate actions to strengthen domestic resource availability of critical information, the tax transparency
mobilisation by reversing IFFs from the continent.11 standards also enable law enforcement authorities to
track, detect and sanction the abuse of legal entities and
INTERNATIONAL TAX TRANSPARENCY STANDARDS AS arrangements for other IFFs activities.
A TOOL TO CURB ILLICIT FINANCIAL FLOWS
IMPACT OF EXCHANGE OF INFORMATION ON
The consensus on curtailing activities that generate REVENUE COLLECTION
IFFs outlines the need for adopting effective tools to
deal with these threats. Because the opacity and secrecy The ultimate aim of EOI is to obtain information that
surrounding the origin and destination of IFFs is at the is relevant for tax investigations, audits and other
heart of the issue, transparency has emerged as one compliance activities. Monitoring the amounts of tax
of the effective tools for combating IFFs. For example, identified through EOI enables the tax administration
since transparency removes the veil of secrecy, it to clearly track its impact on DRM. Yet only 14 out of
renders the use of legal persons and/or arrangements 32 African countries that responded to the TTiA survey
in transactions facilitating IFFs less attractive by monitor the contribution of EOI on revenue collection.
enabling the identification of the legal and beneficial The majority (nine African countries) monitors the tax
owners of legal entities or arrangements. Transparency identified through occasional case-by-case feedback
also provides for the access to banking information received from tax auditors and investigators. Three
and accounting records, which is also fundamental African countries use the Global Forum’s Impact
to identify the origin and destination of the flows. Assessment Tool,12 while two have an automated
Increased transparency therefore makes it easier for tracking system in place.
national authorities to track down individuals and/or
companies involved in illegal activities and to enforce By the end of 2021, Global Forum members had
their laws. identified more than EUR 114 billion of additional
revenues (tax, interests, penalties), thanks to the
Tax transparency is an effective tool in combating tax implementation of the EOIR and AEOI standards,
evasion and other types of IFFs, such as corruption, including the related voluntary disclosure programmes
money laundering and terrorism financing, and (VDPs) and offshore tax investigations, with over
enhances domestic resource mobilisation (DRM). EUR 30 billion identified by developing countries.13
The tax transparency standards, the Standard on In 2022, five African countries reported identifying
9. OECD (2018), Illicit Financial Flows: The Economy of Illicit Trade in West Africa, OECD Publishing, Paris. http://dx.doi.org/10.1787/9789264268418-en.
10. United Nations (2015). Report of the third international conference on financing for development. A/CONF.227/20. Addis Ababa, https://documents-dds-ny.un.org/doc/
UNDOC/GEN/N15/241/03/PDF/N1524103.pdf?OpenElement.
11. AU Commission (2015). Agenda 2063: The Africa we want, https://au.int/sites/default/files/documents/36204-doc-agenda2063_popular_version_en.pdf.
12. The Global Forum’s impact assessment tool is available to tax authorities upon request. For more information:
https://www.oecd.org/tax/transparency/documents/documents-available-to-tax-authorities-upon-request.htm.
13. OECD (2022), Raising the Bar on Tax Transparency, 2022 Global Forum Annual Report, https://www.oecd.org/tax/transparency/documents/global-forum-annual-report-2022.pdf.

TABLE 1. Overview of the tax transparency standards
Transparency and exchange of information on request Automatic exchange of financial account information
The EOIR standard requires a jurisdiction’s competent The AEOI standard requires financial institutions to apply due diligence
authority (CA) – usually, the tax authority – to provide on rules and periodically report information regarding financial accounts
request information to another jurisdiction’s CA that is of tax residents of other jurisdictions to their local CAs. Subsequently,
foreseeably relevant for conducting a tax investigation and to the CAs automatically exchange this information with the CAs of other
enforce its tax laws or the provisions of a tax agreement in force jurisdictions (i.e. the country of tax residence of the account holder).
between two countries. The CRS contains details as to the due diligence process that should
be applied by financial institutions to determine what accounts are
The EOIR standard is built around three pillars of availability,
reportable and the items of information that should be exchanged
access and exchange, which form the basis of its Terms of
amongst other relevant indications.
Reference (ToR).(a)
All members of the Global Forum are committed to the implementation
A. Availability of information: jurisdictions should ensure
of the AEOI standard, whilst not all jurisdictions are expected to
the availability of (i) legal and beneficial ownership information
implement it immediately, due to time needed for them to develop
of all relevant legal entities and arrangements, (ii) accounting
their capabilities. Currently, a total of 123 jurisdictions are committed to
records and underlying documents, and (iii) banking
exchanging financial account information automatically by 2026.(b)
information (including information on legal and beneficial
Jurisdictions implementing the AEOI standard undergo a peer review
owners of account) in banks within the jurisdiction.
process by the Global Forum. The peer reviews are carried out against
B. Access to information: jurisdictions should have the the three Core Requirements (CR) of the AEOI ToR(c):
authority and powers to obtain relevant information for tax
CR 1: jurisdictions should ensure that all reporting financial institutions
purposes, including legal and beneficial ownership, accounting
apply due diligence procedures which are in accordance with the CRS to
and banking information.
review the financial accounts they maintain and collect and report the
C. Exchange of information: jurisdictions should have an information required by the CRS.
international legal basis or mechanism, and an organisation to
CR 2: jurisdictions should exchange information with all interested
be able to exchange information in a timely manner.
appropriate partners(d) in accordance with the AEOI standard, in a timely
All members of the Global Forum have committed to the
manner, ensuring it is sorted, prepared, validated and transmitted in
implementation of the EOIR standard, and the level of
accordance with the AEOI standard.
compliance with this standard, both in terms of the legal
framework and the implementation in practice, is assessed CR 3: jurisdictions should keep the information exchanged confidential
under the Global Forum’s peer review process to ensure a level and properly safeguarded, and use it in accordance with the exchange
playing field. agreement under which it was exchanged.
(a) OECD (2016), Exchange of Information on Request, Handbook for Peer Reviews 2016-2020, available at
https://www.oecd.org/tax/transparency/documents/terms-of-reference.pdf.
(b) Status of AEOI commitments, available at https://www.oecd.org/tax/transparency/aeoi-commitments.pdf.
(c) OECD (2018), The Framework for the full AEOI reviews: the terms of reference, available at
https://www.oecd.org/tax/transparency/documents/terms-of-reference-for-aeoi-reviews.htm.
(d) Interested appropriate partners are those interested in receiving information and that meet the required standards in relation to confidentiality and data
safeguards.
over EUR 76.6 million in additional revenue through The impact of exchange of information on request
the use of EOIR and CRS data, the highest amount
since the establishment of the Africa Initiative in 2014 EOIR is an essential tool to support tax authorities
(see Figure 1). In total, between 2009 and 2022, African worldwide to access taxpayers’ information held
countries have identified over EUR 1.69 billion of abroad and determine whether they are paying their
additional revenues as a result of EOIR, other offshore due taxes. In the context of EOIR, if a country does
tax investigations and VDPs related to AEOI and use of not send requests, it cannot obtain information that
CRS data. This is likely the low range, as the majority is critical to the resolution of tax audits/investigations
of the African respondents are not systematically with a cross-border element. Consequently, potential
monitoring the impact of EOI on DRM, and some African additional tax revenue that may be assessed as a result
countries have not provided data or have not done so for of offshore information may remain out of the reach of
all years. tax authorities.

FIGURE 1. Revenues identified as a result of exchange of information, in EUR million

Total since 2009
1 800
1 692
1 600
1 400
746
1 200
1 000
800
6.2
23.5 30.2 67.0 20.0 14.5 35.1 37.2 76.6 600
945
400
2014 2015 2016 2017 2018 2019 2020 2021 2022
200
0
EOIR and other offshore
investigations
AEOI
(VDPs and use of CRS)
Note: The left figure reflects the situation for 38 African countries which have provided data in the corresponding year. It reflects the revenues generated through EOIR and
the use of CRS data. The right figure takes into account all sources of revenues, namely EOIR and other offshore investigation, as well as VDPs and the use of CRS data.
Source: Tax Transparency in Africa Survey 2023
In 2022, four African countries (Kenya, South Africa, the use of CRS data and EUR 87 billion through VDPs
Tunisia and Uganda) identified additional revenues linked to AEOI.
totalling EUR 66 million through the use of EOIR, almost
equalling the EUR 67 million identified through the For the first time, in 2022, one African country reported
use of EOIR in 2017. Since 2009, African countries have having identified EUR 10.6 million in additional taxes
identified over EUR 310 million through EOIR alone. through the use of CRS data.
THE IMPACT OF AUTOMATIC EXCHANGE OF Since 2018, the five African countries that are
FINANCIAL ACCOUNT INFORMATION exchanging AEOI data have sent information covering
a total of 1.93 million financial accounts with a total
AEOI has also had a positive impact on the fight against value of EUR 363.5 billion. In turn they have received
tax evasion. For example, studies have found that information covering a total of 5.80 million financial
the number of financial assets held in international accounts with a total value of EUR 772.3 billion. The
financial centres declined by 22% since the beginning of number of financial accounts and the aggregate value
AEOI under the CRS.14 of financial accounts for which information was sent
and received by African countries has been increasing
In 2021, information on over 111 million financial steadily over the years, except for 2018 (Figure 2). African
accounts were exchanged under the CRS worldwide, countries that are exchanging AEOI data have received
covering around EUR 11 trillion worth of assets.15 more information than they have sent, indicating the
From 2014 to 2021, countries implementing the potential for AEOI for these countries.
AEOI standard had identified EUR 3.5 billion through
14. O’Reilly, P., K. Parra Ramirez and M. A. Stemmer (2019), “Exchange of Information and Bank Deposits in International Financial Centres”, OECD Taxation Working Papers, No. 46,
OECD Publishing, Paris, https://doi.org/10.1787/025bfebe-en.
15. OECD (2022), Raising the Bar on Tax Transparency, 2022 Global Forum Annual Report, op. cit.

FIGURE 2. Number of financial accounts covered by African countries’ automatic exchanges of information
250 1.80
1.59
1.60
Aggregate value of financial accounts (in EUR billion)
200 1.39
208.89 1.40
182.01 1.20
Number of financial accounts (in million)

1.10
150
0.95 1.00
140.18
0.77 126.60 0.80
123.5
100 114.66 111.6
0.58
0.52 0.60
0.41
0.40
50 71.1
0.25
0.18
0.20
29.6
27.8
0 0.00
2018 2019 2020 2021 2022
Value of FAs (sending information) Value of FAs (receiving information)
Number of FAs (sending information) Number of FAs (receiving information)
Note: The figure represents feedback provided by the five African countries that are exchanging information automatically.
Source: Tax Transparency in Africa Survey 2023.
12th meeting of
8 November 2022,
Seville, Spain.

Section head
Developments
in tax transparency
in Africa in 2022
2 The developments in tax transparency in Africa in 2022 were
hinged around its two strategic pillars:
1. raising political awareness and commitment in Africa
2. developing African countries’ capacities in tax transparency.
AFRICA2023
2023
Developments in tax transparency in Africa in 2022
2022
KEY TAKE-AWAYS
Building strong political buy-in to unpack the domestic resources mobilisation. Moreover, 27 officials
benefit of tax transparency for all African countries from 13 African countries participated in the 2022 edition
of the Train the Trainer Programme and held 21 local
l High-level political engagements in Africa to trainings for 433 tax officials in their respective countries.
promote tax transparency and EOI: In partnership
with the AU Commission, the tax transparency agenda Cross-border assistance in the recovery of tax claims
was promoted through the inclusion of a discussion
on the findings of the TTiA 2022 report in the agenda l Several capacity-building activities were carried out to
of the 5th Specialised Technical Committee on Finance, help African countries build their frameworks for effective
Monetary Affairs, Economic Planning and Integration participation in cross-border assistance in the recovery of
Experts Meeting in July 2022. The Republic of the Congo tax claims, including two meetings of the related Working
(Congo) was welcomed as the 34th member of the Africa Group focusing on the use of the Tax Debt Management
Initiative upon joining the Global Forum. Two new partners Maturity Model and on the development of a toolkit,
(the International Finance Corporation (IFC) and the and an in-country training for Tunisia on this form of
Commonwealth Association of Tax Administrators (CATA)) administrative co-operation.
joined the Africa Initiative. Tunisia committed to implement
the Standard of Automatic Exchange of Financial Account Women Leaders in Tax Transparency
Information by September 2024.
l 8 female tax professionals from 8 African countries
l Yaoundé Declaration: Originally signed by four countries participated in the 2022 Women Leaders in Tax
in November 2017, the Yaoundé Declaration counts Transparency Programme, which promotes increased
33 signatory countries and the AU Commission, Botswana participation of female officials in leading positions of
being the latest signatory. national tax administrations or ministries of finance.
l Tax Transparency in Africa 2022: The 2022 progress African countries’ active contributions to Global
report, reflecting the progress made by the 38 countries Forum work and capacity-building activities
that responded to the survey on the implementation and
the use of the tax transparency standards, was launched at l African countries contributed as members to all Global
the 11th Africa Initiative meeting held in Nairobi, Kenya. Forum’s subsidiary bodies, including the Steering Group
(2 African countries), the Peer Review Group (2 African
Capacity building countries) and the Automatic Exchange of Information
Peer Review Group (3 African countries) and members in
l Technical assistance: 33 African countries received relation to Automatic Exchange of Information Peer Review
technical assistance on various topics including improving Group in its expanded composition, which deals with
the beneficial ownership frameworks, broadening confidentiality and data safeguards (4 African countries).
the EOI networks through the MAAC, improving the
organisation of the tax administrations and setting up l African countries also contributed their technical expertise
of functioning EOI units, strengthening the legal and to exchange of information on request peer reviews
operational framework for AEOI and pre-membership (13 African countries), confidentiality and data safeguard
support. assessments (4 African countries) and the Task Force on
Risks (2 African countries).
l Developing tax officials’ skills in EOI: 15 training events
were held for or with the participation of 1 170 officials l African countries further contributed experts to the
from African countries to ensure effective use of training events organised by the Global Forum Secretariat
EOI instruments to tackle illicit financial flows and increase (2 African countries).

BUILDING STRONG POLITICAL BUY-IN TO UNPACK Engagements were also held with the African
THE BENEFITS OF TAX TRANSPARENCY FOR ALL Development Bank (AfDB) in preparation of its “Executive
AFRICAN COUNTRIES Training Series on Domestic Revenue Mobilisation in Africa
During Crisis and Beyond” in March, May and June 2022.
Three major activities were conducted to unpack the The trainings conducted in collaboration with the
benefit of tax transparency: African Development Institute of the AfDB counted
127 participants from 44 African countries across
l participation in high-level meetings and events diverse institutions, including Ministries of the Economy,
Finance, Planning and Budget; Central Banks; Revenue
l promotion of the Yaoundé Declaration Authorities; Debt Management Offices and other
government agencies. In October 2022, a high-level
l demonstrating the impact of tax transparency and meeting was held with AfDB to further strengthen the
EOI in DRM through the Tax Transparency in Africa collaboration on tax transparency.
Report and Africa Initiative meetings.
Engagement at senior level between the Global Forum
High-level political engagement in Africa at the Secretariat and the ATAF Secretariat continued in 2022
continental and regional levels to advocate for tax to coordinate joint activities in EOI on the continent.
transparency and exchange of information
At the regional level, engagements to champion tax
The Africa Initiative has adopted a three-pronged transparency were held with the West African Tax
approach to advance tax transparency consisting of Administrations Forum (WATAF) Tax Audit Network in
engagement at the continental, regional and country April 2022, where 64 participants attended a session
levels. This approach is based on the grounds that on administrative co-operation tools to support the
there are institutions which play a key role in shaping audit of cross border transactions, as well as the WATAF
the policy decisions aimed at combating IFFs at 4th High-level Policy dialogue held in September 2022,
the continental, regional and local levels. There is on the theme “Boosting Revenue Administration Through
therefore a need to raise awareness on the potential of Efficient Leadership and Corporate Governance“, where the
tax transparency at these levels and advocate for its Global Forum Secretariat participated in a panel and
inclusion in the different political agendas. The ultimate delivered a presentation on “Improving the Use, Exchange,
objective is to ensure a coordinated response to the issue and Security of Taxpayer Information in the Era of Big Data”.
of IFFs, which takes into account the contribution of tax Further engagements were also held at the Cercle de
transparency and EOI. réflexion et d’échange des dirigeants des administrations
fiscales (CREDAF) Annual Conference attended by over
In 2022, the Africa Initiative held discussions with 10 heads of tax administrations of French speaking
partners at continental and regional level in order to African countries in June 2022.
enhance the visibility of transparency and EOI in Africa.
The engagements at the continental and regional levels
At the continental level, several meetings were contributed tangible results on advancing the tax
organised with the AU Commission, including transparency agenda in Africa. For example, the Republic
participation in the 5th Specialised Technical Committee of the Congo, joined the Global Forum and the Africa
on Finance, Monetary Affairs, Economic Planning and Initiative as the 34th African country during the last
Integration Experts Meeting in July 2022.1 The outcomes day of the 11th Africa Initiative meeting held in Nairobi,
from the engagements stressed the importance for Kenya, in June 2022.
countries that have not joined the transparency and
EOI agenda to do so.
1. The AU Commission’s Specialised Technical Committee is the leading Conference for African ministers responsible for finance, economy, planning, integration and
economic development, and central bank governors, to discuss matters about the development of Africa. It is also charged with following up on the implementation of
the integration agenda for the continent. For more see: https://au.int/en/stc.

11th meeting of the Africa Initiative,

14-16 June 2022, Nairobi, Kenya.
Promotion of the Yaoundé Declaration advancing EOI and fight tax evasion and other forms
of IFFs in their respective countries and at the level of
The Yaoundé Declaration2 aimed at boosting African regional economic communities. They also recognised
countries’ efforts towards implementing the the importance of cross-border assistance for the
international standards and using EOI tools to improve recovery of tax claims as complementary to EOI and
their DRM, is an important commitment for African agreed on the need to remove the barriers to this form
countries. Originally signed by four countries in of mutual assistance, including by lifting or avoiding
November 2017, the Yaoundé Declaration currently any reservation in relation to it in MAAC4 and other
counts 34 signatories, including the AU Commission. mutual administrative assistance agreements. Finally,
Its goal is to ensure that African countries take recognising the benefits of participating in the work of
ownership of the tax transparency agenda and promote the Africa Initiative, heads of tax administrations called
it to serve the continent’s interests in fighting tax on non-members to join the international efforts on
evasion and IFFs, thus enhancing DRM. The efforts tax transparency by becoming members of the Global
made, including through the communication by the Forum and the Africa Initiative.
Africa Initiative leadership to countries that had not
yet signed the Yaoundé Declaration, culminated in 2022 progress report
Botswana joining as 34th signatory of the Yaoundé
Declaration in March 2022. Demonstrating the impact of EOI on DRM is of
profound importance for the Africa Initiative, as it
The Africa Initiative took advantage of its June 2022 provides evidence on the benefits and importance
meeting to celebrate the 5th anniversary of the Yaoundé for governments to prioritise tax transparency as a
Declaration during a high-level working dinner with concrete tool to tackle tax evasion and other IFFs to
heads of tax administrations. The statement of enhance DRM. It also has a positive impact on taxpayer
outcomes3 recognised that the African Continental compliance and increases the public perception of
Free Trade Area (AAfCFTA) Agreement currently at its the tax systems’ fairness. The TTiA report, which is
implementation stage brings new opportunities but also published annually, serves this purpose.
new risks on DRM, as it will ultimately lead to increased
cross-border economic activities within Africa. The The TTiA survey, which facilitated the preparation of
heads of tax administrations therefore committed to 2022 TTiA report, was launched in January 2022. The
2. More details on the Yaoundé Declaration can be found at this link:

https://www.oecd.org/tax/transparency/what-we-do/technical-assistance/the-yaounde-declaration.htm.
3. Statement of outcomes of the 11th Africa Initiative meeting held from 14-16 June 2022, Nairobi, Kenya:
https://www.oecd.org/tax/transparency/documents/11th-meeting-of-the-africa-initiative-statement-of-outcomes.pdf.
4. OECD and Council of Europe (2011), The Multilateral Convention on Mutual Administrative Assistance in Tax Matters: Amended by the 2010 Protocol, OECD Publishing, available
at http://dx.doi.org/10.1787/9789264115606-en; and https://www.oecd.org/tax/exchange-of-tax-information/ENG-Amended-Convention.pdf.

Africa Initiative leadership encouraged both members Delegates also discussed how African countries could
and non-members of the Africa Initiative to provide overcome barriers to AEOI implementation and build
responses to the questionnaire, and 38 countries effective beneficial ownership frameworks in Africa.
(32 members and 6 non-members)5 responded. The Finally, they also shared experiences and agreed to
responses resulted in the 2022 TTiA report,6 a joint establish the essential building blocks for participation
publication by the AU Commission, ATAF and the in cross-border assistance in the recovery of tax claims,
Global Forum, which was launched at the 11th Africa including by recommending lifting or avoiding any
Initiative meeting held in June in Nairobi, Kenya. This reservation in relation to this form of co-operation in the
fourth edition of the report reflected significant progress MAAC and other mutual administrative agreements.
made by the 38 countries in the implementation
and the use of the tax transparency standards, Engaging with civil society organisations
including the continued expansion of the networks of
EOI relationships, the increasing number of requests Civil society organisations are influential voices on
sent, the growing commitment to AEOI and the increase matters which affect the society at large and play
in revenue identified through EOI. an important role in advancing the tax transparency
agenda on the continent. In recognition of this, the
Peer-to-peer knowledge sharing Africa Initiative incorporates their perspectives during
its meetings. In 2022, civil society organisations
The Africa Initiative promotes peer-to-peer learning participated in the 11th Africa Initiative meeting held
on tax transparency. This is premised on the belief in Nairobi, Kenya in June 2022, including as a panellist
that African countries can collectively realise the full during the launch of the 2022 TTiA report. They
potential of EOI if they are able to share best practices commented on the findings of the TTiA and took note
and learn from each other and from other regions. In of the progress made and the remaining challenges for
this respect, the Africa Initiative annual meetings offer a African countries to fully benefit from tax transparency.
unique platform for knowledge and experience sharing
among African countries through the discussion of topics CAPACITY BUILDING IN 2022
that may advance the tax transparency agenda in Africa.
The second pillar the Africa Initiative focused on in 2022
The 11 Africa Initiative meeting was an onsite meeting,
th
related to developing capacities to ensure that African
which attracted over 150 delegates from 32 African countries are able to use the tax transparency standards
countries, including 7 non-members,7 20 partners and to enhance their DRM. This took the form of technical
donors of the Africa Initiative, and invited organisations. assistance, trainings and other capacity-building support.
In addition to the onsite attendance, the first day of the
meeting was a public session held in a hybrid format, Technical assistance
which was attended by 159 participants online.
With the support of partners and donors of the Africa
Topics selected for discussion were very important Initiative, intensive technical assistance continued to be
and enabled peer learning.8. They included discussions delivered to African countries in 2022 through induction
linking EOI to DRM, how African countries can translate programmes, tailored assistance programmes and pre-
progress made in establishing EOI infrastructures into membership support, covering multiple areas of EOIR or
revenue gains and how to measure the impact of EOI. AEOI (33 countries supported in total on the continent):
5. The following countries provided answers to the survey: Algeria, Angola, Benin, Botswana, Burkina Faso, Cabo Verde, Cameroon, Chad, Congo (Republic of the),
Côte d’Ivoire, Djibouti, Egypt, Eswatini, Gabon, Gambia, Ghana, Kenya, Lesotho, Liberia, Madagascar, Malawi, Mali, Mauritania, Mauritius, Morocco, Namibia, Niger, Nigeria,
Rwanda, Senegal, Seychelles, Sierra Leone, South Africa, Tanzania, Togo, Tunisia, Uganda and Zimbabwe.
6. OECD (2022), Tax Transparency in Africa 2022: Africa Initiative Progress Report, https://www.oecd.org/tax/transparency/documents/tax-transparency-in-africa-2022.pdf.
7. Angola, Burundi, Congo (Republic of the), Sierra Leone, South Sudan, Zambia and Zimbabwe.
8. The following jurisdictions and partners intervened during the meeting to share their experience or their perspective on the various topics discussed: Belgium,
Cameroon, France, Ghana, Kenya, Lesotho, Nigeria, Seychelles, South Africa, Togo, Tunisia, Uganda, AfDB, ATAF, AU Commission, CREDAF, CATA, European Union, Extractive
Industry Transparency Initiative, IFC, International Monetary Fund, Japan, OECD, Oxfam, Tax Justice Network – Africa, UNECA, WATAF and World Bank.

l Improving the beneficial ownership regime: ongoing considered by other countries. Further, the support
support to strengthen beneficial ownership legal led to actions taken by Botswana which resulted
and implementation frameworks was delivered to in a positive response from the Peer Review Group9
16 African countries. As a result, Rwanda, Uganda to Botswana’s request for a supplementary review10
and Tanzania amended their legal frameworks for against the EOIR standard.
beneficial ownership and similar changes were
BOX 1. Implementation strategy for automatic exchange of financial account information
The Strategy is based on a modular approach that divides While modules 1 to 3 take place successively, modules 4 to 7
technical assistance programmes into several coherent can be initiated simultaneously or consecutively, and in the
and logical modules with specific targets to be achieved in relevant order, based on the particular circumstances of the
order to move from one module to another. In line with the jurisdiction. As for module 8 on assistance on effective use
Global Forum’s broader 2020 Capacity-Building Strategy, of exchanged data, it is considered a continued assistance.
the modular approach is implemented to ensure a better
allocation of resources and improved monitoring.
Modular approach for the AEOI implementation

Monitoring of the delivery on the commitment / quick reaction mechanism Continued assistance
MODULE 1
MODULE 4
Initial engagement
ISM technical
and commitment
assistance
to the project
Exchange
Formalised commitment to the project
MODULE 5
of data
Legal framework
technical assistance
MODULE 2
Preliminary ISM
assessment and
work plan
MODULE 6
Exchanging data MODULE 8
support Upon completion Assistance on effective
Effective engagement in the project
of Modules 4-7 use of exchanged
data
MODULE 3 Formal commitment to MODULE 7
Detailed ISM maturity a date of first exchanges Administrative compliance
assessment, action plan
assistance
and formal commitment
Modules 1-3 are successive Modules 4-7 can be initiated simultaneously or consecutively,
and in the relevant order, depending on the circumstances of the jurisdiction
Source: OECD (2021), Unleashing the potential of automatic exchange of information for developing countries,
https://www.oecd.org/tax/transparency/documents/aeoi-strategy-developing-countries.pdf.
9. The Peer Review Group (PRG) oversees the Global Forum’s peer reviews in relation to the EOIR Standard. It consists of 30 Global Forum members and meets three to four
times a year to discuss and approve the peer review reports and proposals on other matters related to the review of the EOIR Standard, which are then submitted for
adoption by the Global Forum. For more information see: https://www.oecd.org/tax/transparency/who-we-are/structure/.
10. A jurisdiction which has received unsatisfactory rating in the EOIR peer review but has subsequently made significant improvements by addressing recommendations
made by the Global Forum has the opportunity to have these improvements evaluated by the Global Forum and any determinations or ratings updated accordingly
through a process known as a “supplementary review”. More information on supplementary reviews is available in the 2016 methodology for Peer reviews and Non-
Member Reviews: https://www.oecd.org/tax/transparency/documents/methodology-eoir-peer-reviews_12-2020.pdf.

l Broadening EOI networks through the MAAC: were successful, and they were cleared to undertake
ongoing support and guidance was provided to reciprocal exchanges. In 2022, African countries
12 African countries at different steps of joining continued to benefit from the technical assistance
the MAAC, including the submission of the request through the modular approach (see Box 1), which has
to be invited to sign the Convention, the signing of proven very effective for the implementation of AEOI.
the Convention, and the deposit of instrument of It was specifically designed to unleash the potential of
ratification. As a result, Madagascar signed the MAAC AEOI for developing countries.
on 7 July 2022, while Angola was invited to sign it on
10 May 2022. Mauritania, Rwanda and Burkina Faso Developing tax officials’ skills in exchange of
deposited their instruments of ratification on 29 April, information
29 August and 13 December 2022 respectively, with
the MAAC entering into force on 1 August 2022, Capacity building is one of the core duties of the Global
1 December 2022 and April 2023. Egypt started the Forum. It aims at supporting and enabling a rapid
process to join the MAAC at the end of 2022. and effective implementation of the tax transparency
standards by all members, in particular developing
l Improving the organisation of tax administrations ones. The objective is also to ensure that all members
and setting up of functioning EOI units with effectively benefit from the standards to access tools
appropriate tools: ongoing support and guidance to combat tax evasion and other IFFs, and raise more
was provided to seven African countries, including resources to finance their own development. Since the
practical perspectives and options for strengthening establishment of the Africa Initiative in 2014, the Global
the EOI infrastructure. Forum has worked with the partners and donors to the
Africa Initiative to enhance the capacities of African tax
l Pre-membership support was provided to four administrations in tax transparency.
African countries. Information on the benefits and
commitments upon joining the Global Forum was Training
shared with these countries. They were also invited to Various training for officials, to ensure effective use of
attend the 11th and the 12th Africa Initiative meetings EOI instruments to tackle IFFs and increase DRM, were
as observers, to understand the progress made and organised during 2022. In total, 15 training events were
compare their respective countries with African held for or with the participation of 1 170 officials from
peers. In the margins of these events, the Global African countries as indicated in Table 2.
Forum Secretariat held bilateral meetings with their
representatives to discuss their possible participation Train the Trainer programme
in the tax transparency work and offered more tailored Amongst its ground-breaking capacity-building
support where needed. initiatives designed to build sustainable EOI capacity in
African tax administrations, the Global Forum Secretariat
l Strengthening the legal and operational framework launched a “Train the Trainer” pilot programme in 2021.
for AEOI: 10 African countries were supported at The one-year programme is designed to ensure that
different stages of the AEOI implementation, including tax administrations are equipped with knowledgeable
establishing appropriate information security officials who can deliver quality and frequent trainings
management frameworks (7 countries), developing in EOI, hence increasing local ownership of EOI technical
enabling legal frameworks (6 countries), formulating skills. The programme, which encompasses both hard
administrative compliance strategies (3 countries), and soft skills, is structured to ensure intense support
putting in place a portal for receiving information from by the Global Forum Secretariat, with participants being
financial institutions (2 countries) and making effective provided all necessary tools for the delivery of training
use of CRS data (1 country). As a result of the support sessions tailored to the context of their jurisdiction.
provided, Tunisia committed to implementing the
AEOI standard with first exchanges in September 2024. The pilot programme, which was attended by
In addition, Ghana and Kenya’s pre-exchange 34 participants from 17 African countries, proved its
confidentiality and data safeguards assessments high productivity. Trainers from the 2021 programme

TABLE 2. 2022 capacity-building events on exchange

of information for African countries BOX 2. Kenya’s experience with
the Train the Trainer programme
Topic Date
Two officials from the Kenya Revenue
EOI for tax auditors 22 February 2022 Authority (KRA) successfully participated in the pilot
Train the Trainer programme in 2021. KRA organised the
Workshop on AEOI Common 24 February 2022
Transmission System following events which allowed the two certified trainers
to spread the knowledge and build the skills of their
Fundamentals in International 3 March 2022 colleagues in EOI:
Taxation
l two training sessions in 2021 for 162 tax officials
Beneficial ownership training 17 March 2022
l three training sessions in 2022 for 118 tax officials
Role of EOI in supporting audit 28 April 2022
cases l one sensitisation session in 2022 for 184 tax officials.
Beneficial ownership training 17-18 May 2022 In total, the two trainers from the KRA delivered 5 training
sessions to 280 tax officials and 1 sensitisation session
Beneficial ownership training 19-20 May 2022 attended by 184 tax officials.
Setting up effective EOI Units 23-25 May 2022 The impact of these training events is visible on the use
of EOI in Kenya as the KRA is experiencing a significant
AEOI implementation 23-26 May 2022
increase in the number of EOI requests, with over 150
EOI for tax auditors 25 June 2022 requests made annually since 2021, as compared to 73
requests made in 2020 and 17 requests made in 2019.
Cross-border assistance in the 20-22 September 2022
recovery of tax claims Kenya’s future plans regarding further training include,
but are not limited to the following:
Effective use of the MAAC 30 October - 2 November 2022
l continue to actively engage the participants in the
EOI as a tool to combat offshore 22 to 24 November 2022
Train the Trainer programme to train the tax officials,
tax evasion
especially tax auditors and investigators
Information Security 18-21 December 2022
Management l train about 100 tax officials each year
Beneficial Ownership 22 December 2022

l have face-to-face training sessions with smaller
groups for more interactive sessions and a deeper
Source: Table produced by the Global Forum Secretariat based on internal database. understanding by the trainees
l engage the Kenya School of Revenue Administration

collectively held 43 local trainings for 1 375 tax officials
to add the EOI training as one of the units to its
in the participating countries. Most importantly, the
curriculum
local trainings held in 2021 are already indicating
a positive impact on the use of EOI by participating l train any new officers who join the Competent
countries as illustrated by Kenya’s experience (see Authority Office
Box 2).
l offer technical assistance or capacity building
requested by partner jurisdictions.
Following the resounding success of the pilot phase
in Africa, the Global Forum Secretariat expanded the
Train the Trainer programme in 2022 to cover more
African countries. Table 3 shows the overall results of Source: Kenya Revenue Authority, in OECD (2023), New Horizons in Capacity
Building for Tax Transparency: 2023 Global Forum Capacity Building Report,
the 2021 and 2022 programmes for Africa, while Box 3 https://www.oecd.org/tax/transparency/documents/2023-global-forum-
highlights the experience of one participant to the capacity-building-report.pdf.
2022 edition of the programme.

TABLE 3. Overall results of the Train the Trainer programme in 2021 and 2022 in Africa
2021 cohort 2022 cohort Total

Number of countries 17 13 29
Number of participants (trainers) 34 27 61
Female participation (%) 47% 44% 45.5%
Number of trainings proposed to be delivered 34 28 62
Number of trainings delivered 43 21 63
Number of officials trained (1)

1 375 433 1808
Female participation (%) 30% 41% 35.5%
Note: the figures on the 2021 cohort include the local trainings organised in 2021 and 2022.
(1)
The figures are as of 31 December 2022.
Source: OECD (2023), New Horizons in Capacity Building for Tax Transparency: 2023 Global Forum Capacity Building Report,
https://www.oecd.org/tax/transparency/documents/2023-global-forum-capacity-building-report.pdf.
BOX 3. Testimony from a participant in the 2022 edition of Train the Trainer
Mr Mamoudou Fofana, Head of Research Division, also included case studies and a quiz, which
Directorate of Research, Investigations and Support to Audit, were very fruitful and allowed the attendants
Directorate General of Taxes, Mali to better understand certain theoretical aspects of the
modules.
As a former auditor of the Large Taxpayer Directorate, I had a
clear idea of the importance of an exchange of information Following my participation in the programme, I have
request for combating tax fraud and improving the results been selected to deliver training sessions on exchange
of tax audits. While I had previous learning experience of information as part of the training programme of the
through the e-learning modules of the Global Forum and Directorate General of Taxes in 2023. The tax administration
the participation in a Last Mile seminar, attending the Train trusts that continued participation in the programme will
the Trainer programme has been an opportunity for me to contribute to the enlargement of the circle of local trainers
further deepen my knowledge of exchange of information for the perpetuation and improvement of the training
and to continue to contribute to the dissemination of this activities. Finally, I plan to participate in a training session on
knowledge within my tax administration. the peer review process in order to be able to participate in
future peer reviews as an assessor and therefore prepare the
The programme allowed me to contribute to the training
evaluation of Mali through the lessons learned.
of 25 executives of the Mali tax administration on exchange
of information on request. The training course was a Source: Directorate General of Taxes of Mali in OECD (2023), New Horizons
in Capacity Building for Tax Transparency: 2023 Global Forum Capacity Building
breakthrough for many participants who followed with Report, https://www.oecd.org/tax/transparency/documents/2023-global-forum-
interest the different modules presented. The course capacity-building-report.pdf.
Women leaders in tax transparency countries (Eswatini, Kenya, Liberia, Mauritius, Senegal,
In 2022, the innovative programme “Women Leaders South Africa, Togo and Uganda).
in Tax Transparency” was launched to make a decisive
contribution towards a sustainable increase in female The one-year programme requires participants to
leadership in tax transparency. It promotes increased prepare in advance of all sessions through the reading
participation of female officials in leading positions of technical material, attending e-learning modules
of national tax administrations. The programme was and preparing documents to support discussion and
attended by 22 female tax officials from 22 developing experience sharing. Six sessions were organised and
members of the Global Forum, including 8 African focused on central aspects of tax transparency, such

BOX 4. Women Leaders in Tax Transparency 2022 Programme
l February 2022: initial meeting focused on legal aspects Bahamas and Ms Elizabeth Guerrero, former Vice Minister
of the EOIR standard, with mentoring sessions opened of Revenue of Costa Rica and former Chair of the Latin
by Ms Grace Perez-Navarro, Deputy-Director of the OECD America Initiative.
Centre for Tax Policy and Administration, Patron of the
l July 2022: fourth meeting focused on the international
2022 programme, and by Ms Zayda Manatta, Head of the
tax agenda, with the participation of Ms Marlene
Global Forum Secretariat.
Nembhard-Parker, Deputy Commissioner General of the
l March 2022: second meeting centred on the AEOI Jamaican Tax Administration and Co-Chair of the Base
standard and the beneficial ownership standard with Erosion and Profit Shifting (BEPS) Inclusive Framework,
the expertise of Ms Wendy Roelandt, Advisor-General and Ms Huey Min Chia-Tern, Deputy Commissioner of the
and Head of International Relations at the Federal Public Inland Revenue Authority of Singapore and then Chair of
Service Finance of Belgium, with the participation of Ms the Global Forum Peer Review Group.
Maria José Garde, General Director of Taxes in the Spanish
l September 2022: fifth meeting centred on a leadership
Ministry of Finances and then Chair of the Global Forum
training for women, with the participation of a certified
(2017-2022), and of Ms Ana Cebreiro, Senior Economist
trainer.
and Global Tax Program Manager at the World Bank.
l October 2022: final meeting of the 2022 pilot edition
l May 2022: third meeting focused on the practical
with a feedback session and the launch of the Women
aspects of EOIR, in particular the concept of foreseeable
Leaders in Tax Transparency network.
relevance with the expertise of Ms Miek Haller, Deputy
Head of the Service for Exchange of Information,
Source: OECD (2023), New Horizons in Capacity Building for Tax Transparency: 2023
Switzerland, with the participation of Ms Rowena Bethel,
Global Forum Capacity Building Report, https://www.oecd.org/tax/transparency/
International Tax Information Exchange Specialist, documents/2023-global-forum-capacity-building-report.pdf.
Women leaders in tax transparency lunch meeting, 10 November 2022, Seville, Spain.

as the tax transparency standards and the broader transformative effect in increasing the participation and
international tax agenda, as well as leadership trainings leadership of women in tax transparency.
and mentoring sessions delivered by experienced
women in the tax transparency field (see Box 4). The A network to enhance co-operation on information
Women Leaders in Tax Transparency network has been security management
formed and will continue to expand in the coming years. At the 2021 Global Forum plenary meeting, the Secretariat
The network, which will meet regularly, constitutes launched an information security management
a forum to discuss the upcoming tax transparency (ISM) network as a platform for Global Forum members
agenda, as well as any challenge in the implementation to share best practices and experiences, creating a
of the EOI standards with the aim to empower women. community to improve confidentiality and data safeguards
As shown in Box 5, the programme can have a frameworks. As a platform for interaction and sharing
BOX 5. A testimony on the Women Leaders in Tax Transparency 2022 programme:

interview with Ms Felicia Powson – Liberia
Why did you decide to participate in the 2022 Women The organisers ensured participants studied
Leaders in Tax Transparency Programme? the e-learning modules and toolkits before each session
by preparing presentations tailored to each jurisdiction’s
My decision to participate in the 2022 Women Leaders in
position on every module learned and actively participated
Tax Transparency Program (WLITT) was based on the main
in every session.
objectives outlined in the programme: addressing gender
inequality, ensuring diverse decision-making across every The programme impacted me in the following ways:
sphere of taxation, promoting female leadership in tax
l As a career woman, I learned to seize every opportunity
transparency, especially in our EOI Program. And creating
to first empower myself by acquiring adequate skills
a female network to ensure further co-operation and
and technical proficiency in improving my career
experience sharing in tax administration.
development.
Working in a male-dominated environment, where the
l I have learned to set my professional and personal
views of women are usually overlooked, I am faced with
improvement plans by aligning myself with experienced
challenges of not being considered in decision making. This
personalities mentoring me along the path of meeting
led me to take advantage of the opportunity to attend the
my goals.
series of trainings, seminars and courses to enhance my
capacities and address the challenges outlined herein. l Making impact wherever I find myself by speaking and
finding solutions to challenges at hand.
What has been your experience and what was the
impact of participating in the programme? l Lastly, I learned to build my self-confidence and take
advantage of opportunities in horning my skills and
My experience as a participant, throughout the 9 months
voicing out my strength.
program was an exceptional learning experience. Being in
attendance with highly skilled and experienced women What are the next steps planned in Liberia Revenue
leaders with diverse disciplines from around the world Authority to continue to enhance women’s leadership in
was a privilege and an inspiration in expanding my career tax transparency?
pathway.
The LRA is initiating a continuous peer-gathering
The programme was excellently organised. In every step programme that will create the platform twice a year
of the way, the organisers maintained consistency in for females to exchange ideas and experience among
accordance with the objectives set out in the programme. themselves, so as to attain the skills required to make
The presenters and mentors were resourceful and open in quality decisions in the workspace.
sharing their personal and professional journeys in pursuing
their goals. Source: Liberia Revenue Authority

of experiences between jurisdictions, including both l A three-day training in September 2022, held in Tunis,
developed and developing members, the network plays an Tunisia, under the technical assistance programme
important role in the development of confidentiality and in tax matters for Tunisia, funded by the EU and
data safeguards across all Global Forum members. attended by 31 Tunisian officials. The training raised
awareness on the challenges and opportunities of the
The ISM network currently gathers more than cross-border assistance in recovery of tax claims as
200 nominated representatives from 65 jurisdictions – a tool to support DRM. Following this, a joint ATAF
including 9 African members. In addition, the “ISM network and Global Forum regional workshop on this form of
Live Hour” was launched to discuss key ISM topics administrative assistance for African countries was
proposed by the network’s experts on a quarterly basis. planned to take place in 2023.
Four sessions have so far been conducted and attended by
10 participants from African members. Topics discussed l The work on a toolkit on cross-border assistance in
included vulnerability management, insider threat, recovery of tax claims was launched. The toolkit is
incident management, investigation and breach reporting, intended to assist interested Global Forum members
and secure use of personal mobile devices. in the implementation of the related function within
their administrations. The launch of the toolkit
CROSS-BORDER ASSISTANCE IN THE RECOVERY OF is planned for 2023 and it will support the future
TAX CLAIMS technical assistance work in this area.
A working group on cross-border assistance in the recovery Feedback from the survey for the TTiA 2023 report
of tax claims in Africa (Working Group) was created in demonstrates continued interest in this form of
March 2021 within the framework of the Africa Initiative. administrative assistance. In 2022, five African countries
The Working Group conducted a fact-finding exercise to sent eight requests for cross-border assistance in the
understand the current position of African countries on recovery of tax claims. In the same year, three African
this form of cross-border assistance and to ascertain the countries received nine requests to provide assistance in
conditions necessary for its effective use. The result of this tax recovery.
fact-finding exercise was summarised in a note, approved
at the 10th Africa Initiative meeting in November 2021.11 AFRICAN COUNTRIES’ ACTIVE CONTRIBUTIONS TO
The note highlighted the need for building capacities GLOBAL FORUM WORK AND CAPACITY-BUILDING
in Africa in order to unlock the potential of this form of ACTIVITIES
administrative co-operation for DRM.
The capacity-building activities undertaken over the
In 2022, capacity-building activities have been carried years have resulted into more experience and knowledge
out to help African countries build their frameworks for on EOI acquired by African countries. This in turn has
an effective cross-border assistance in recovery of tax led to increased participation of African countries in
claims. This included: the global tax transparency work. Their participation
brings the technical expertise and perspective of
l Two meetings of the Working Group held in April and African countries to the discussions and decisions of
in October 2022, with a focus on the assessment of the Global Forum. African countries contribute to all
domestic tax debt management maturity using Global Forum’s subsidiary bodies13 and provide technical
the Tax Debt Management Maturity Model12 and the experts for peer reviews and capacity-building activities
discussion of the outline of a guidance tool on cross- (see Table 4).
border assistance in recovery of tax claims.
11. A summary of the note can be found at this link: https://www.oecd.org/tax/transparency/documents/cross-border-assistance-recovery-of-tax-claims-african-countries.pdf.
12. OECD (2019), Tax Debt Management Maturity Model, OECD Tax Administration Maturity Model Series, OECD, Paris. www.oecd.org/tax/forum-on-tax-administration/
publications-and-products/tax-debt-management-maturity-model.htm.
13. Steering Group, the Peer Review Group (PRG) and the Automatic Exchange of Information Peer Review Group (APRG). More information on the work and composition of
these bodies is available at https://www.oecd.org/tax/transparency/who-we-are/structure/.

TABLE 4. Participation of African countries in Global Forum’s bodies and capacity-building activities in 2022
Steering Group The Steering Group is made up of 20 members. It 2 African countries are members of the Steering
prepares and guides the future work of the Global Group and one of them also holds the position of
Forum. Vice-Chair: Kenya and South Africa.
Peer Review Group for The Peer Review Group (PRG) is made up of 2 African countries are members of the PRG:
Exchange of Information 30 members and oversees the Global Forum’s peer Kenya and Uganda.
on Request (PRG) reviews in relation to the EOIR standard.
Automatic Exchange of The APRG is made up of 30 members and oversees the 3 African countries are members of the APRG:
Information Peer Review work on peer reviews against the AEOI standard. Ghana, Mauritius and South Africa.
Group (APRG)
Automatic Exchange of The APRG+ is an extended formation of the APRG 4 African countries are members of the APRG+:
Information Peer Review which oversees the peer reviews on confidentiality and Ghana, Mauritius, South Africa and Uganda.
Group (APRG+) data safeguards.
Assessors on EOIR The EOIR assessors are responsible for conducting the 13 African countries provided EOIR assessors:
peer reviews of jurisdictions against the EOIR standard. Burkina Faso, Cameroon, Gabon, Ghana, Kenya, Liberia,
All members are invited to provide assessors. Mauritius, Morocco, Nigeria, Senegal, South Africa, Togo,
and Uganda.
Assessors on The assessors on confidentiality are responsible for 4 African countries provided assessors for the
confidentiality conducting the assessments on confidentiality and confidentiality peer reviews:
data safeguards. Kenya, Lesotho, Mauritius and South Africa.
Experts in capacity- Experts from Global Forum members participate to 2 African countries shared their expertise and
building activities capacity-building activities carried out, providing experience in capacity-building activities:
expertise and sharing experience. Cameroon and Tunisia.
Task Force on Risks The Task Force on Risks was established to identify 2 African countries participated in the work of the
new or emerging issues/risks to the effective Task Force on Risk: Kenya and Uganda.
implementation of the standards on transparency and
exchange of information for tax purposes.
Note: This table reflects the participation of African countries in Global Forum’s bodies and capacity-building activities as of December 2022. With effect from 1 January 2023,
African countries took on new roles in the leadership of the Global Forum bodies for the period 2023 to 2025, which is not reflected in this report. For more information:
https://www.oecd.org/tax/transparency/who-we-are/structure/.
Source: Table produced by the Global Forum Secretariat based on internal database.
As shown by Box 6, African countries that actively and other organisations, as WATAF and CREDAF, actively
contribute to the work of the Global Forum bodies’ also contributed to the Initiative’s activities. Support from the
build their capacities in the implementation of the tax donor community, namely from France, the European
transparency standards. Union, Norway, Switzerland and the United Kingdom
was essential to develop country-specific projects.
PARTNERSHIPS TO SUPPORT AFRICAN COUNTRIES The World Bank also endorsed the African Initiative’s
activities and worked with the Global Forum Secretariat
In 2022, African countries continued benefitting from the to strengthen the collaboration in Africa.
support of the long-standing partners and observers of
the Africa Initiative, which opened to new contributions. While enhancing synergies with existing partners, new
The different partnerships covered both region-wide collaborations were initiated. The IFC, a member of the
initiatives and country-specific programmes, to unlock World Bank Group, and CATA were welcomed as partners
the full potential of multi-stakeholder involvement of the Africa Initiative at the 11th Africa Initiative
and bespoke assistance. Africa’s superregional political, meeting in Nairobi, Kenya, strengthening collaboration
financial and tax-related institutions and organisations with key international and regional institutions
- the AU Commission, the AfDB and ATAF - continued to to promote the tax transparency agenda. CATA,
play a major role in supporting the Initiative. Regional Christian Aid, the the Extractive Industry Transparency

BOX 6. Uganda’s contribution to the Global Forum’s work
Q1: Uganda joined the Global Forum in 2012 and became Uganda as a member of the PRG brings the
a member of the PRG in 2017. Uganda has been a member developing country context to the discussions
of the PRG since then. In addition to implementing the for a more inclusive and fit-for-purpose peer review process.
EOIR standard, Uganda has committed to implement the
Lastly, Uganda prides itself in being at the forefront of
AEOI standard with the first exchanges in September
championing the regional participation in tax transparency
2023. In this regard, Uganda became a member of the
and EOI as a strategic response to the challenge of tax
APRG+ in 2020. Uganda has been recently confirmed to
evasion and IFFs out of Africa. The peer reviews occasionally
take part in the 2023-2025 mandate of both the PRG and
bring to bear legal regimes and practices designed to
the APRG+, which represents a significant commitment
undermine the progress made in tax transparency and
of time and resources to the global tax transparency
information sharing. Therefore, Uganda’s participation in
work. Why is the participation in both Global Forum’s
the peer review process is an affirmation of the trust and
bodies and its long-standing commitment important to
confidence the country as a whole has in the credibility
Uganda? What is the importance of the representation of
and soundness of the framework for transparency and
developing countries in the distinct Global Forum bodies?
information exchange among members regardless of their
Uganda’s continuous and active involvement in tax geographical location and size of economy.
transparency including membership in the Global Forum
In summary, between 2014 and 2017, Uganda progressed
Peer Review Group (PRG) and AEOI Peer Review Group
from a country without a dedicated EOI unit to becoming
(APRG+) was by design. In 2014, a series of conscious
an active member of the PRG and APRG+ and a powerhouse
decisions were made, at a strategic level, that would
on the continent. As a nation, we are proud to contribute to
later shape the practice of EOI in Uganda, i.e. a phased
the growing list of African countries that have served and
adoption of the standards, delegation of the role of the
continue to contribute to this important work.
Competent Authority and creation of the EOI unit, the level
of strategic representation and engagement, consensus
Looking ahead, the combined efforts of the PRG and
across government on the long-term objectives and key
APRG+ hold significant potential for advancing global tax
milestones among others. These key steps were formally
transparency. The future work of these bodies will involve
documented in an EOI strategy in 2019.
ongoing assessments, peer reviews, and the refinement of
Therefore, Uganda’s long-term commitment to the peer standards to address emerging challenges and changing
review process through strategic representation at the PRG international tax landscapes. Collaboration among member
and APRG+ is first and foremost reflective of the country’s countries, including Uganda, will continue to shape
commitment to respect of international law and treaty international tax policies and ensure that the benefits of tax
obligations arising from participation in international and transparency are realized at both the national and global
regional organisations. The peer reviews also serve to levels.
safeguard the interests of all parties, Uganda included, by
Q2: In addition to its membership of the PRG and APRG+
promoting adherence to the agreed standards including
and hosting Global Forum events, Uganda has provided
timely and reliable information sharing to support DRM
assessors for EOIR peer reviews of other Global Forum
efforts and the National Development Agenda.
members over the years. Why is it important for Uganda
Secondly, the experience from the PRG enables developing to contribute to the EOIR review process?
countries build a critical mass of highly skilled and
It is important for Uganda to contribute to the peer review
professional human resource that can ably interpret,
process for several reasons:
evaluate and apply the tax transparency standards in the
everchanging universe of taxation and globalisation. The First and foremost, the peer review process provides a proof
methodology and terms of references for conducting peer of concept that EOI works. The review process evaluates the
reviews have been reviewed through a comprehensive and effectiveness of countries’ mechanisms for exchanging
consultative process spearheaded by the PRG. Therefore, Continued...

Box 6 continued... as a nation that is committed to and cooperative in the

global battle against tax evasion. This may inspire more
information, which is essential for detecting and deterring
confidence in other nations, international organisations,
cross-border tax evasion. Uganda’s participation confirms its
and investors. Furthermore, Uganda’s involvement in
commitment to promoting international collaboration and
the review process strengthens its voice and influence in
sustaining a network of information exchange.
establishing worldwide tax transparency norms.
Secondly, it provides a platform to sharing best practices
l Promoting global tax fairness: EOI is a fundamental
and skills: Assessors, working with the Global Forum
component of international efforts to ensure that
apply their knowledge and skills in context of correctly
all taxpayers meet their tax obligations. Uganda’s
diagnosing blockades to efficient functioning of EOI from
engagement in the review process reflects the country’s
a practical perspective. This results in recommendations
support for the global principles of transparency,
that speak to the reality of the assessed jurisdiction and
accountability, and fair tax practices that EOI promotes.
overall advancement on the transparency agenda. Overall,
participation in this process positively impacts the efficacy l Capacity building: through the peer review process,
and effectiveness of tax transparency measures around Ugandan representatives gain a deeper understanding of
the world as a result of the contribution of the assessors international tax transparency standards, guidelines, and
and implementation of recommendations by the assessed best practices. They become aware of the requirements
Jurisdictions. These lessons are replicated back home. and expectations for effective implementation. This
knowledge enhances their capacity to develop and
l Strengthening systems. Uganda has the opportunity
refine their tax transparency frameworks.
to benchmark on more advanced mechanisms for
exchanging information (both upon request and In summary, Uganda’s contribution to the peer review
automatically). Uganda has identified areas for process is essential for enhancing international cooperation,
development and improvement in its own systems with sharing best practices, strengthening its own systems,
the assistance of the evaluation and recommendations building influence, promoting global tax fairness and
obtained through the review process. This improves capacity building. By actively participating in the review
Uganda’s tax transparency structure and guarantees that process, Uganda plays a crucial role in advancing tax
it complies with global norms. transparency efforts worldwide and supporting the global
fight against tax evasion.
l Building influence: by actively participating in the
EOIR review procedure, Uganda strengthens its standing Source: Uganda Revenue Authority.
Initiative (EITI) International Secretariat, IFC, Oxfam commitment to advancing the tax transparency agenda
and the United Nations Economic Commission for in Africa, contribute to curb IFFs and improve DRM.
Africa (UNECA) were also in attendance for the first Both the 11th and 12th Africa Initiative meetings and the
time, demonstrating the wide-spread support to the tax Global Forum Plenary were important occasions where
transparency agenda in Africa. In addition, Belgium and partners could exchange their views and contributed to
Japan supported the work of the Africa Initiative in 2022. strengthening their engagements in the Initiative.
ECOWAS, the International Monetary Fund (IMF), the
OECD, Tax Justice Network Africa, and the WAEMU all Table 5 summarises the collaboration with partners in
participated in the 11th Africa Initiative meeting in 2022. 2022.
Partner’s participation strongly underscores their

Section head
11th meeting of
14-16 June 2022,
Nairobi, Kenya.
TABLE 5. Flagship initiatives by Africa Initiative’s partner
Partner Initiative Impact

AU Commission TTiA report co-authorship Continental
TTiA report co-authorship Continental

ATAF
Joint capacity-building activities with GF in transparency and EOI for African countries. Country specific
Pilot project to support Senegal in establishing its legal and institutional framework for AEOI Country specific
and improve the use of EOIR in its tax compliance activities
AfDB
Public Financial Management Capacity Development programme that comprises six critical Continental
areas including DRM and Accountability, Transparency and Curbing of Corruption and IFFs
CREDAF Workshop on the establishment and operation of effective EOI units Regional
Support to Global Forum technical assistance programme Continental
European Union West Africa Tax Transition Support Programme Regional
Capacity building activities in Egypt and Tunisia Country specific

France
AEOI implementation pilot project in Morocco Country specific
Norway Support to Global Forum technical assistance programme Continental

Switzerland
AEOI project technical support to Tunisia Country specific

United Kingdom Implementation of AEOI for Kenya and Uganda as well as in strengthening Egypt’s EOI Country specific
processes and legal framework
Session of the Tax Audit Network on administrative co-operation tools to support the audit of Regional
WATAF cross border transactions
High-level Policy Dialogue Regional
World Bank Support to Madagascar on joining the MAAC Country specific
Source: Table produced by the Global Forum Secretariat based on internal database.

Section head
African countries’
progress in
implementing the tax
transparency standards
3 African countries have continued strengthening their
EOI infrastructures by broadening their EOI networks and
enhancing their legal and regulatory frameworks, as well as the
organisation of the EOI function. Despite the progress made,
more work is needed on the implementation of beneficial
ownership transparency and the AEOI standard.
AFRICA2023
2023
African countries’ progress in implementing the tax transparency standards
2022
KEY TAKE-AWAYS
Strengthening infrastructures for exchange Implementation of the standard for exchange

of information on the continent of information on request
Broadening exchange of information networks Peer reviews of the exchange of information on request
l Africa’s EOI network has reached over 3 070 EOI relationships, standard
of which 66% (2 039) were created by the MAAC only, 13% l Since the beginning of the second round of EOIR peer
(409) are bilateral/regional relationships complemented by reviews in 2016, nine African countries have been fully
the MAAC and 20% (629) are bilateral/regional relationships reviewed by the Global Forum (legal and regulatory
only. framework and implementation in practice) and five have
been subjected to a review of the legal and regulatory
l Two more African countries brought the MAAC into force,
framework only (Phase 1 review).
bringing the total of African countries with the MAAC in
force to 18 (33% of all African countries). l Of the nine African countries fully reviewed, one is overall
“Compliant”, four are overall “Largely Compliant” and the
l Intra-African EOI relationships amount to 667, compared to
remaining four are overall “Partially Compliant”.
2 410 EOI relationships with jurisdictions outside of Africa.
46% (606) of the intra-African EOI relationships in force are Transparency of beneficial ownership in Africa
created under the MAAC, compared to 89% (2 142) for l No African countries is rated “Compliant” with respect to
EOI relationships with jurisdictions outside Africa. ownership & identity information, which is largely influenced
by the beneficial ownership transparency (Element A.1).
Enhancing the organisation of the exchange of information
Three African countries are rated “Largely Compliant”, while
function
the remaining six are rated “Partially Compliant”.
l 33 African countries have delegated the Competent
Authority function to the appropriate level within the tax
Implementation of the standard of automatic
administration, 28 have established EOI units, 24 have in
exchange of information on financial accounts
place an EOI manual and 23 use a tracking tool to monitor
the impact of EOI.
Increasing participation of Africa in AEOI
l The number of officials assigned to EOI has grown by 42% l Five African countries are exchanging information
since 2021, reaching 175 officials in 2022. The number automatically on a reciprocal basis. Five more African
of training events held in 2022 almost doubled and the countries are committed to implementing AEOI within the
number of staff trained increased by 26%, totaling 1 613 tax next three years.
officials and 73 internal training events, mainly thanks to the
Broad network of exchange partners under the CRS
Train the Trainer programme in which African countries have
Multilateral Competent Authority Agreement (CRS-MCAA)
been participating since its launch in 2021.
l The five African countries exchanging information
automatically have a total of 374 AEOI bilateral
relationships activated.
Outcomes of the AEOI peer reviews (legal frameworks and

effectiveness in practice) for African countries
l The legal and regulatory framework of three out of the five
African countries exchanging CRS data were considered
as “In Place but Needs Improvement”. Improvements are
also needed in the effective implementation of AEOI as the
effectiveness reviews rated one country as “On Track”, one
as “Partially Compliant”, and one as “Non-Compliant”, while
the remaining two are yet to be reviewed.

STRENGTHENING INFRASTRUCTURES FOR EXCHANGE OF INFORMATION ON THE CONTINENT
A jurisdiction cannot effectively implement and benefit Broadening exchange of information networks
from international tax co-operation without putting
in place a minimum level of EOI infrastructure. At A legal instrument in force between two or more
the base is a broad network of EOI agreements that jurisdictions provides the basis for international
provides a legal gateway for co-operation with other tax co-operation. A wide network of such legal
jurisdictions and an enabling domestic legal and instruments provides a country with the legal gateway
regulatory framework. This should be complemented for co-operation with a large number of jurisdictions.
by appropriate organisational structures and processes. Broadening the network of African countries
This includes a delegation of the Competent Authority EOI relationships is therefore part of the core stage of
powers to the appropriate level within the tax the 2021-2023 Africa Initiative mandate.
administration, establishing a well-resourced EOI unit
to handle inbound and outbound requests and other As of 31 December 2022, African countries have entered
type of EOI data, such as data received spontaneously into 1 636 bilateral l EOI relationships based on bilateral
or automatically, a process manual that documents or regional agreements, of which 1 136 are in force (see
and guides tax administration officials involved in the Figure 3). These EOI relationships take the form of double
EOI function and a mechanism for tracking requests taxation conventions (DTCs), tax information exchange
FIGURE 3. Bilateral and regional instruments for exchange of information in force in African countries (by type)
120
DTC TIEA AMATM AMU CEMAC EAC DTC SADC WAEMU ECOWAS
100
80
60
40
20
0
Algeria
Angola
Benin
Botswana
Burkina Faso
Burundi
Cabo Verde
Cameroon
Central African Republic
Chad
Comoros
Congo (DRC)
Congo (Rep. of the)
Côte d'Ivoire
Djibouti
Egypt
Equatorial Guinea
Eritrea
Eswatini
Ethiopia
Gabon
Gambia
Ghana
Guinea
Guinea-Bissau
Kenya
Lesotho
Liberia
Libya
Madagascar
Malawi
Mali
Mauritania
Mauritius
Morocco
Mozambique
Namibia
Niger
Nigeria
Rwanda
Sao Tome and Principe
Senegal
Seychelles
Sierra Leone
Somalia
South Africa
South Sudan
Sudan
Tanzania
Togo
Tunisia
Uganda
Zambia
Zimbabwe
Note: Bilateral agreements include double tax conventions (DTCs) and tax information exchange agreements (TIEAs). Regional agreements include all agreements
listed in Footnote 1 on page 43.
Source: Analysis done by the Global Forum Secretariat based on publicly available information.

FIGURE 4. Percentage of African countries’ instruments for exchange of information meeting the standard
(by type, MAAC not included)
100%
22 1 22
(3%) (1%) (2%)
Yes
176
(46%)
No 678
(60%)
501 Unreviewed
(73%)
50% 66
(99%)
210
(54%)
437
(38%)
161
(24%)
0%
DTCs Regional agreements TIEAs Total
Note: The labels show the number of EOI instruments that meet the EOI standard based on exploitable data, and the corresponding percentage in brackets. 22 DTCs are not
available in English or French, and no analysis could be conducted on them, hence they are referred to as unreviewed.
agreements (TIEAs) and regional agreements1 that provide Unlike bilateral and regional agreements, multilateral
a basis for international co-operation in tax matters. EOI instruments assist jurisdictions to rapidly expand
their EOI networks through a single signature, instead
While countries have the option to negotiate and of negotiating EOI agreements with each jurisdiction.
conclude bilateral or regional agreements for EOI, Of all multilateral instruments, the MAAC is the widest-
it can be a resource-intensive and time-consuming reaching EOI agreement with already 147 participating
exercise. In addition, some of the bilateral and jurisdictions4, out of which 137 had it in force as of
regional EOI Agreements may not be in line with the December 2022. In addition, the MAAC is in line with the
model provision in Article 26 of the OECD Model Tax EOIR standard and further provides for AEOI and other
Convention on Income and Capital (OECD Model Tax forms of administrative co-operation.
Convention)2 and the United Nations Model Double
Tax Convention between Developed and Developing Since 2014, the Global Forum Secretariat, under the
Countries (UN Model Tax Convention).3 Indeed, 60% of umbrella of the Africa Initiative, has provided technical
the bilateral and regional agreements concluded by support to its African members to expand their
African countries for international co-operation in tax administrative co-operation frameworks rapidly by
matters do not allow for EOI to the full extent provided joining the MAAC, including support in the signing and
in the OECD and UN models provisions (see Figure 4). ratification process (see Box 7). In 2022, these efforts
1. These include the ATAF Agreement on Mutual Administrative Assistance in Tax Matters (the AMATM); the Convention for the Avoidance of Double Taxation and the Establishment
of Rules for Mutual Assistance in respect of Taxes on Income between the States of the Arab Maghreb Union (AMU); the Southern Africa Development Community’s
Agreement on Mutual Assistance in Tax Matters (SADC Agreement); the Economic Community of West African States (ECOWAS) Supplementary Act 5/12/18 Adopting
Community Rules for the Elimination of the Double Taxation with Respect to Taxes on Income, Capital and Inheritance and the Prevention of Tax Evasion and Avoidance
within the ECOWAS Member States (ECOWAS Supplementary Act 5/12/18); the Central African Economic and Monetary Community Agreement Regulation n°07/19 of 7 April
2019, revising Act n°5/66 of 13 December 1966 on the avoidance of double taxation; the East African Community Double Taxation Convention (EAC DTC); and the West Africa
Economic and Monetary Union (WAEMU) Regulation No. 08/2008 adopting rules for the avoidance of double taxation within WAEMU and rules on assistance in tax matters.
2. OECD (2017), Model Tax Convention on Income and on Capital: Condensed Version 2017, OECD Publishing, Paris, https://doi.org/10.1787/mtc_cond-2017-en.
3. UN (2017), Model Tax Convention between developed and Developing Countries, UN, New York, https://www.un.org/esa/ffd/wp-content/uploads/2018/05/MDT_2017.pdf.
4. As of June 2023, there are 147 participating jurisdictions, including Viet Nam, which is the most recent signatory.

culminated in one more country (Madagascar) signing TABLE 6. Participation of African countries in the
the MAAC, while three others (Burkina Faso, Mauritania Convention on Mutual Administrative Assistance in
and Rwanda) completed their domestic ratification Tax Matters, as on 31 December 2022
processes and deposited their instruments of
ratification. Country Status
Angola Invitation to sign the MAAC (2021)
As of December 2022, African countries had 3 077 EOI
Benin Signed (2019)
relationships in force, of which 2 039 are built on the MAAC,
409 are bilateral/regional relationships complemented Botswana In force (2021)
by the MAAC and 629 are bilateral/regional relationships Burkina Faso Deposit of instrument of ratification (2022)
that do not overlap with the MAAC (see Figure 5). Figure 6
Cabo Verde In force (2020)
shows that, out of the 3 077 EOI relationships, the MAAC
covers a total of 2 448 EOI relationships, complementing Cameroon In force (2015)
409 bilateral/regional relationships as indicated above. In
Eswatini In force (2021)
addition, 18 African countries had ratified and brought
the MAAC into force, compared to 16 in 2021 (see Table 6), Gabon Signed (2014)
with three additional African countries being signatories Ghana In force (2013)
to the MAAC (Gabon, Madagascar and Togo). Even though
Kenya In force (2020)
the signature of tax conventions constitutes an important
step towards increased tax transparency, the completion of Liberia In force (2021)
the domestic ratification processes remains indispensable Madagascar Signed (2022)
to fully benefit from EOI and other forms of international
Mauritania In force (2022)
tax co-operation. All signatories are strongly encouraged to
conclude their domestic ratification processes and deposit Mauritius In force (2015)
the instruments of ratification for the MAAC to come Namibia In force (2021)
into effect and provide a legal gateway for international
Morocco In force (2019)
co-operation in tax matters.
Nigeria In force (2015)
Only 23 African countries, all members of the
Rwanda In force (2022)
Global Forum and the Africa Initiative, have signed
the MAAC, which means more than half of African Senegal In force (2016)
countries are not yet in a position to take advantage Seychelles In force (2015)
of the opportunities presented by this international
South Africa In force (2014)
instrument, which provides for extensive forms of
mutual assistance in tax matters. Togo Signed (2020)
Tunisia In force (2014)

All the African countries with a wide EOI network
Uganda In force (2016)
are members of the Global Forum and the Africa
Initiative and are signatory to the MAAC (see Figure 5). Note: Burkina Faso deposited its instrument of ratification on 13 December 2022
In general, African countries which are not member and the MAAC came into force on 1 April 2023; Benin deposited its instrument of
ratification on 24 January 2023, and the MAAC came into force on 1 May 2023
of the Africa Initiative tend to have a narrow network
Source: Jurisdictions participating in the MAAC –
of EOI relationships. This is because upon joining the https://www.oecd.org/tax/exchange-of-tax-information/Status_of_convention.pdf.
Global Forum and participating in the Africa Initiative,
countries understand the importance of international
agreements for an effective EOI and receive support
to join the MAAC. Figure 6 shows the evolution of
the number of EOI relationships created by African
countries since 2014 and the impact of the MAAC on
their EOI networks.

BOX 7. Rwanda and Madagascar: Participation in the Convention on Mutual Administrative Assistance
in Tax Matters
Rwanda Madagascar
Rwanda joined the Global Forum in December In 2022, a very important step was taken by
2017. At that time, Rwanda had signed only Madagascar after it joined the Global Forum in
eight bilateral DTCs and the East African 2017: Ms Rindra Hasimbelo Rabarinirinarison,
Community DTC which covered five countries. This Minister of Economy and Finance of Madagascar, signed
limited EOI network restricted Rwanda’s ability to request the MAAC on 7 July 2022. This important milestone was
information to support tax audits or investigations with a achieved with the support of the Global Forum Secretariat,
cross-border element to a few countries. which provided technical assistance, in particular with
regard to confidentiality, and the World Bank.
With the support of the Global Forum Secretariat through
the new member induction programme, which started in Signing the MAAC can bring several advantages to
2018, Rwanda signed the MAAC in August 2021. Madagascar, including:
Rwanda swiftly completed its domestic ratification l Combatting tax evasion and avoidance to increase DRM
procedures and deposited the instrument of ratification in and the fairness of the tax system: the implementation of
August 2022. This was possible due to the collaboration of the MAAC will enable Madagascar to access ownership,
the various stakeholders within the Government of Rwanda accounting and banking information held abroad.
who had been informed of the implications of joining the This can help the country ascertain the position of its
Global Forum as well as the expectations placed upon taxpayers’ cross-border transactions and affairs.
Rwanda. This included the need to have a wide network
l Increased transparency: the MAAC requires signatories
of EOI bilateral relationships that could enable Rwanda to
to exchange information in tax matters. This increased
exchange information with as many jurisdictions as possible.
transparency can help Madagascar identify areas of
The importance of the MAAC as legal gateway for rapidly
non-compliance, improve tax administration and reduce
increasing Rwanda’s EOI network without engaging in costly
opportunities for tax evasion.
and time-consuming bilateral discussions and negotiations
with other jurisdictions had also been highlighted. l Attracting foreign investment: international investors
are often concerned about the transparency and
Consequently, the MAAC entered into force in Rwanda in
predictability of a country’s tax system. By signing the
December 2022, enabling Rwanda to have an EOI network
MAAC, Madagascar can demonstrate its commitment to
with already 146 other jurisdictions of which 137 had it in
international tax standards, which can increase investor
force as of December 2022. Without the MAAC, Rwanda
confidence and promote foreign investment.
would have had only 13 EOI bilateral relationships in force.
Overall, the MAAC can bring significant benefits to
As a large EOI network in line with the international
Madagascar, including increased revenue, improved tax
standards is one of the building blocks for the
administration, and a more attractive investment climate.
implementation of the AEOI standard, Rwanda has
To that end, after the signing in 2022, the next step is now
leveraged joining the MAAC to commit to implementing the
for Madagascar to ratify the MAAC and to deposit the
AEOI standard with first exchanges in September 2025.
instrument of ratification, therefore ensure it entry into
Source: Rwanda Revenue Authority.
force.
Source: Directorate General of Taxation of Madagascar.

FIGURE 5. African countries’ exchange of information relationships in force

160
140
120
100
80
60
40
20
0
Algeria
Angola
Benin
Botswana
Burkina Faso
Burundi
Cabo Verde
Cameroon
Central African Republic
Chad
Comoros
Congo (Dem. Rep. of the)
Congo (Rep. of the)
Côte d'Ivoire
Djibouti
Egypt
Equatorial Guinea
Eritrea
Eswatini
Ethiopia
Gabon
Gambia
Ghana
Guinea
Guinea-Bissau
Kenya
Lesotho
Liberia
Libya
Madagascar
Malawi
Mali
Mauritania
Mauritius
Morocco
Mozambique
Namibia
Niger
Nigeria
Rwanda
Sao Tome and Principe
Senegal
Seychelles
Sierra Leone
Somalia
South Africa
South Sudan
Sudan
Tanzania
Togo
Tunisia
Uganda
Zambia
Zimbabwe
Bilateral/regional relationships only Bilateral/regional relationships complemented by the MAAC MAAC only
Total 629 (20%) 409 (13%) 2 039 (66%) 3 077
0 500 1 000 1 500 2 000 2 500 3 000 3 500
Note: This figure only takes into account the agreements which are in force.
While the EOI relationships of African countries and 89% (2 142) are EOI relationships created under
continue to expand, a majority of these relationships the MAAC
are with countries outside the continent and the
EOI relationships between African countries remain The low number of EOI relationships between African
limited (see Figure 7). jurisdictions may limit the ability of African countries to
exchange information with one another. This may have
l African countries have 667 EOI relationships amongst negative implications for the implementation of the
themselves (intra-African relationships) and have Africa Free Continental Trade Area (AfCFTA) Agreement,
2 410 EOI relationships with jurisdictions outside of which entered into force in 2019 and is aimed at creating
Africa. the world’s largest free trade area bringing together
all African countries and the eight Regional Economic
l Out of the 667 intra-African EOI relationships, 46% Communities. As part of its mandate, the AfCFTAis
(306) are EOI relationships created without the MAAC, aimed at eliminating trade barriers and boosting
and 54% (361) are EOI relationships established by the intra-Africa trade. While it offers new opportunities
MAAC. to increase the tax base in African countries, as a
consequence of increased trade, the implementation
l Out of the 2 410 extra-African EOI relationships, 11% of the AfCFTA may also create opportunities for intra-
(268) are EOI relationships created without the MAAC, Africa cross-border tax evasion. It is therefore imperative

FIGURE 6. Number of exchange of information relationships in force established by African countries

since 2014 (worldwide)
3 500 20
EOI relationships created under the MAAC EOI relationships without the MAAC African countries with the MAAC in force 18
18
3 000
16
629 16
(20%)
Number of countries with the MAAC in force

2 500 618 14
(23%)
12
12
2 000
10
484 10
9 9 9 (24%)
1 500 474
(29%) 8
7
469 2 448
461 (33%) (80%)
(34%) 2 112
409 6
1 000 (77%)
(34%)
1 500
392 (76%) 4
3 (44%) 1 180
500 882 972 (71%)
360 792 (67%)
(66%) (66%)
(69%) 2
490
168 (56%)
(31%)
0 0
2014 2015 2016 2017 2018 2019 2020 2021 2022
for African countries to have legal gateways for FIGURE 7. Intra-African and non-African exchange of
exchanging information with one another to effectively information relationships (as of December 2022)
enforce their respective domestic tax laws to combat
100%
any cross-border tax evasion that may arise as intra- 268
(11%)
Africa trade increases.
361
One possibility or rapidly expanding intra-African (54%)
EOI relationships is by joining multilateral agreements Relationships

without
such as the MAAC and the African regional EOI the MAAC
50% 2142
agreements. As noted above, of all multilateral (89%)
EOI agreements, the MAAC has the broadest coverage Relationships
created under
as it counts 146 participating jurisdictions in December 306
the MAAC
(46%)
20225, of which 137 had it in force as of December 2022.
Therefore, joining the MAAC would enable African
countries to expand their EOI relationships with each 0%
Intra-African EOI instruments Extra-African EOI instruments
other and with other countries outside Africa. In
Source: Analysis done by the Global Forum Secretariat based on publicly available
addition, the MAAC is in line with the standard and information.
provides for other forms of administrative assistance.6
5. As of June 2023, there are 147 participating jurisdictions, including Viet Nam, which is the most recent signatory.
6. For more about the MAAC, see OECD (2020), A Toolkit for Becoming a party to the Convention on Mutual Administrative Assistance in Tax Matters,
https://www.oecd.org/tax/transparency/documents/Convention-on-Mutual-Administrative-Assistance-in-Tax-Matters-Toolkit-en.htm.

Enhancing the function for exchange of information In 2022, African tax authorities continued to improve
in Africa their EOI infrastructures. Indeed, 37 out of 38 African
countries that responded to the survey have delegated
Functional EOI infrastructures are essential to meeting the CA status and functions to the tax administration.
obligations under the international standards, including However, only 30 have established a unit to manage
timely processing of EOI requests and providing quality the EOI function. Further, only 25 have an EOI manual
responses and sending quality requests to foreign documenting the handling of EOI requests and 23 have
partners. A well-resourced dedicated unit is a critical a tracking tool to monitor the handling of EOI requests.
component of the EOI infrastructure, as it is responsible Figure 8 shows the EOI infrastructures of African
for managing day-to-day EOI operations. It requires countries as of December 2022.
knowledgeable staff and working processes guided
by a manual, which ensures the handling of requests Well-trained staff are crucial for managing an efficient
in a timely manner while protecting the confidentiality and sustainable EOI unit. The number of officials
of treaty exchanged information. The EOI unit should assigned to EOI has grown rapidly since 2014, when it
also adopt tracking tools to monitor the effectiveness was reported 25 officials worked on EOI. In 2022, there
and the contribution of EOI towards DRM. Moreover, were 175 officials of which 120 (69%) are fully dedicated
the jurisdiction should ensure that the power of to EOI, while 55 (31%) also handle other duties in
Competent Authority (CA) for EOI for tax purposes7 is addition to their EOI responsibilities (mostly in countries
delegated from the Minister in charge of finance – as that have indicated a low volume of EOI activity). African
generally mentioned in EOI agreements – to the tax countries have also intensified efforts to train tax
administration. Delegating the CA status and functions auditors and EOI staff, holding 73 internal training events
to the EOI unit increases operational efficiency and in 2022, which facilitated knowledge and skills transfer to
effectiveness in EOI processes. 1 613 tax officials. As shown by Box 8, consistent training
by tax authorities can contribute to the dissemination
Building strong and efficient EOI infrastructure is a key of the potential of EOI amongst tax auditors, which can
component of the Global Forum’s capacity-building lead to a higher number of requests for information.
programme as it empowers members not only to comply The number of training events held almost doubled and
with the tax transparency standards by providing the number of staff trained increased by 26% compared
information to their partners but, more importantly, to to 2021. In many countries this is explained by their
use this infrastructure to obtain critical information for participation in the Train the Trainer programme
their tax operations. (see Table 7 and Train the Trainer programme).
FIGURE 8. African countries’ infrastructure for exchange of information (2022)
Competent EOl
EOl unit EOl
authority tracking
in place manual
delegation tool 23
In place 25 (61%)
30 (66%)
37 (79%)
(97%)
Not in place
Note: This graph reflects the situation of 38 countries that responded to the Tax Transparency in Africa Survey 2023.
7. CAs are generally the ministers in charge of Finance or their duly authorised representatives, which, depending on the specific organisation of each jurisdiction, may be
the officials of the ministry of finance or the tax administration.

TABLE 7. Domestic capacity building on exchange of information in Africa
Number of events/staffs trained 2021 2022

Number of training events held for tax auditors/EOI staff 37 73
Number of tax of tax auditors/EOI staff trained 1 193 1 613
Note: This table is based on responses from 26 African countries who responded to the question in the survey.
BOX 8. Tunisia: Enhanced training to improve the performance of exchange of information
The Directorate General of Taxation (DGI) has invested In 2022, 252 tax officials participated in six
massively on the implementation of EOI in Tunisia, including virtual and face-to-face training workshops on
through the training of its staff on this topic. EOI held by the Global Forum, while 165 tax auditors
participated in four training sessions on EOI organised by
During the period 2015 to 2019, 532 auditors and
the DGI.
investigators of the DGI involved in the EOI process at
the central and regional levels benefited from more than Overall, 1 969 tax officials have been trained on EOI and
10 training sessions delivered in Tunis and in the regions related topics over the past seven years. This has contributed
by staff members of the International EOI Unit and experts significantly to the dissemination of the EOI knowledge
from the Global Forum. across the tax administration and explains the progress
made by Tunisia in fighting cross-border tax evasion through
The face-to-face training sessions were interrupted in 2020
EOI as seen in the number of requests sent below:
due to the COVID-19 pandemic. Therefore, the training
courses were carried out virtually during 2020 and 2021 and Year No. of requests
covered the following topics: 2018 121
l Exchange of information: 524 participants 2019 269
l Use of the Foreign Information Exchange for Tax 2020 285

Purposes System “EREFF”: 85 participants 2021 264
2022 250
l IT security: 347 participants
l Ethics: 64 participants In 2022 alone, Tunisia identified additional revenue totalling

EUR 11.3 million from the information received.
Source: Directorate General of Taxes, Tunisia.
The EOI knowledge differs greatly between members on Knowledge Sharing Platform (KSP)8, followed by
and non-members. Over 80% of members rate their trainings delivered by participants from the Train-the-
EOI knowledge as high (22%) or medium (59%). In Trainer Programme, toolkits, and recorded trainings
contrast, 60% of non-members rate the EOI knowledge (see Figure 9).
as low and 40% as medium. African countries with
high EOI knowledge attribute it to their participation IMPLEMENTATION OF THE STANDARD FOR EXCHANGE
in trainings organised by the Global Forum, by ATAF, OF INFORMATION ON REQUEST
and locally by the tax administration, including within
the framework of the Global Forum’s Train the Trainer One of the main commitments for all members
programme. African members primarily use e-learnings Global Forum is to be peer-reviewed by the against
8. Available at https://ksp-ta.org/.

FIGURE 9. Percentage of African countries using Global Forum resources for acquiring and disseminating
knowledge and skills on exchange of information
Knowledge Recorded
Sharing Platform training(s)
Train-the-Trainer
82% Programme Toolkit(s) 43%
65% 50%
Note: The figures indicate the percentage of African countries that use the respective resources provided by the Global Forum for acquiring and disseminating knowledge
and skills on exchange of information.
the EOIR standard, including the legal and regulatory To date:

framework and its effectiveness in practice.9 The
monitoring and peer review processes provide assurance l Out of the thirty-seven African members, twenty have
to the Global Forum members that all jurisdictions are undergone an EOIR peer review during the first and/
properly implementing the standard and highlight areas or second round of reviews (see Table 8).
where improvements are needed.
l Fourteen African members have been peer reviewed
Peer reviews of the standard on transparency and in the second round of reviews. Out of this, nine have
exchange of information on request been subject to a full review (a review of the legal
and regulatory framework and its implementation in
The first African countries to become members of practice), five have been subjected to a review of the
the Global Forum were peer-reviewed against the legal and regulatory framework only (Phase 1 review)
EOIR Terms of Reference (ToR) adopted in 2010 in a as no onsite visit could not be undertaken due to the
first round of evaluation. Since then, more and more COVID-19 pandemic (Côte d’Ivoire, Gabon and Kenya)
African countries have joined the Global Forum and or due to limited or no experience in EOIR (Tanzania
have been or will be peer-reviewed in the second round and Togo).
of evaluations against the EOIR ToR that were revised
in 2016, to, amongst others, include requirements to l Twenty-two African members are yet to be subjected
maintain beneficial ownership information on legal to either a full review or a Phase 1 review under the
persons and arrangements and bank accounts.10 second round of EOIR peer reviews.
9. The peer review takes the form of a combined review or a phased review. A combined review, which is the default option of review in Round 2, is a simultaneous review
of both the legal and regulatory framework and the practical implementation of this framework by the jurisdiction. It implies the organisation of an onsite visit a couple
of months after the launch of the review. In November 2021, the Global Forum adopted further amendments to the Methodology for EOIR peer reviews, resulting in the
possibility for jurisdictions with no or limited practical EOIR experience to undergo an EOIR peer review in two phases. A phased review is a review with two phases: the first
phase aims at assessing the legal and regulatory framework (Phase 1), and the second phase aims at assessing the implementation of this framework in practice (Phase 2).
In the context of a phased review, the onsite visit is organised only during the second phase of the review, which would take place a few years after the Phase 1 review.
10. The 2016 EOIR ToR introduces a requirement that beneficial ownership information be available for EOIR purposes in respect of legal persons (e.g. companies,
foundations and limited liability partnerships) and legal arrangements (e.g. trusts). Other improvements have been introduced regarding the coverage of enforcement
measures and record retention periods, foreign companies, rights and safeguards, and the completeness and quality of EOI requests and responses.

The results of the nine African countries in the second purpose of the assets and/or the origin of the funds
round of evaluations against the EOIR standard indicate or assets can be hidden. Anonymity can be enhanced
that: by using other mechanisms, such as bearer shares or
nominee shareholders or directors, or legal entities or
l Only one African country (Mauritius) was legal arrangements, such as trusts, shell companies
rated overall Compliant, while four were rated and other similar structures. Ultimately, the identity
Largely Compliant (Morocco, Nigeria, Tunisia and of the “true owner(s)”, which is the beneficial owner(s),
South Africa). The remaining four countries obtained may be concealed from tax authorities and other law
an overall rating of Partially Compliant (Botswana, enforcement agencies.
Ghana, Liberia and Seychelles).
The EOIR standard requires every jurisdiction to ensure
l Compared to the first round of reviews, one country the availability of beneficial ownership information
improved its overall rating from Largely Compliant for all relevant legal entities and arrangements
to Compliant (Mauritius), one had its overall rating (Element A.1) and for all bank accounts (Element A.3)
downgraded from Compliant to Largely Compliant and to ensure that tax administrations are able to obtain
(South Africa), two maintained a Largely Compliant the information needed to assess taxpayers’ activities,
overall rating (Morocco and Nigeria), three had their no matter where these are carried out. The availability of
overall ratings downgraded from Largely Compliant beneficial ownership information implies that adequate,
to Partially Compliant (Botswana, Ghana and accurate and uptodate information on the identity of the
Seychelles). beneficial owners is held by an information holder in the
jurisdiction, i.e. a person having possession of or control
l Two countries were reviewed for the first time over records or information. In addition, availability
during this round and attained an overall rating of is ensured only where there are clear recordkeeping
Largely Compliant (Tunisia) and Partially Compliant obligations, effective supervision and enforcement
(Liberia). measures in the jurisdiction.
The main causes of the downgrades in the overall The EOIR standard relies on the internationally
ratings of African members have mainly been accepted definition set up by the Financial Action Task
gaps in meeting the enhanced requirements in Force (FATF) to combat money laundering and financing
the 2016 EOIR ToR for ensuring the availability of of terrorism. The FATF Recommendations11 define the
beneficial ownership information for legal persons and beneficial owners as the natural persons who ultimately
arrangements (Element A.1) and gaps in requesting and own or control a legal person or a legal arrangement.
providing information in a timely manner (Element C.5).
As described in Box 9, in March 2022 the FATF adopted a
Transparency of beneficial ownership in Africa stronger global beneficial ownership standard regarding
legal persons, by revising Recommendation 24 and its
Transparency of beneficial ownership plays a Interpretive Note to explicitly require countries to use
significant role in tax transparency, the integrity of a multi-pronged approach, i.e. to use a combination of
the financial sector and law enforcement efforts. Tax different mechanisms for ensuring the availability of
evasion and other forms of IFFs, such as corruption beneficial ownership information for AML purposes.
and moneylaundering, may be facilitated through the
misuse of legal entities and arrangements (companies, The outcomes of the second round of reviews
foundation, partnerships, trusts, etc.). By using complex regarding the implementation of beneficial ownership
chains of ownership of legal persons and arrangements requirements in Africa varies from one country to
across many jurisdictions, the identity of the “true another. Table 9 summarises the determinations and
owners” of assets, including financial ones, the true ratings received by African countries for Element A.1.
11. FATF (2023), International Standards on combating money laundering and the financing of terrorism & proliferation, the FATF Recommendations,
FATF, Paris, France, https://www.fatf-gafi.org/content/dam/recommandations/FATF%20Recommendations%202012.pdf.coredownload.inline.pdf.

TABLE 8. African members compliance ratings against the exchange of information on request standard*
African member Round 1 rating Round 2 rating

Algeria Not reviewed Launch scheduled for Q4 2024
Angola** Not reviewed Q1 2026
Benin Not reviewed Launch scheduled for Q4 2023
Botswana Largely Compliant Partially Compliant (Launched Supplementary Review in Q1 2023)
Burkina Faso Largely Compliant Launch scheduled for Q4 2023
Cabo Verde Not reviewed Launch scheduled for Q3 2024
Cameroon Largely Compliant Launched in Q1 2023
Chad Not reviewed Launch scheduled for Q1 2024
Congo (Rep. of the) Not reviewed Launch scheduled for Q4 2025
Côte d’Ivoire Not reviewed Phase 1 only (Phase 2 scheduled for Q4 2023)***
Djibouti Not reviewed Launch scheduled for Q3 2023
Egypt Not reviewed Launched Q4 2022
Eswatini Not reviewed Launch scheduled for Q2 2024
Gabon Largely Compliant Phase 1 only (Phase 2 scheduled for Q1 2025)***
Ghana Largely Compliant Partially Compliant
Guinea Not reviewed Launch scheduled for Q3 2024
Kenya Largely Compliant Phase 1 only (Phase 2 launched in Q4 2022)***
Lesotho Largely Compliant Phase 1 review launched in Q2 2022
Liberia Not reviewed Partially Compliant
Madagascar Not reviewed Launch scheduled for Q4 2023
Mali Not reviewed Launch scheduled for Q3 2024
Mauritania Largely Compliant Launched Q1 2023 (Phase 1 only)
Mauritius Largely Compliant Compliant
Morocco Largely Compliant Largely Compliant
Namibia Not reviewed Launch scheduled for Q3 2024
Niger Not reviewed Launch scheduled for Q1 2024
Nigeria Largely Compliant Largely Compliant
Rwanda Not reviewed Launch scheduled for Q4 2023
Senegal Largely Compliant Launch scheduled for Q3 2023
Seychelles Largely Compliant Partially Compliant (Supplementary Review launched in Q3 2022)
Sierra Leone** Not reviewed Not yet scheduled
South Africa Compliant Largely Compliant
Tanzania Not reviewed Phase 1 only (Phase 2 scheduled for Q3 2024)****
Togo Not reviewed Phase 1 only (Phase 2 scheduled for Q3 2026)****
Tunisia Not reviewed Largely Compliant
Uganda Largely Compliant Launch scheduled for Q2 2023
Zimbabwe** Not reviewed Not yet scheduled
* The four possible ratings allocated after a full peer review are as follows, ranked in increasing quality: Non-Compliant, Partially Compliant, Largely Compliant, Compliant.
** Became a Global Forum and Africa Initiative member in 2023
*** Subject to a Phase 1 review due to the COVID-19 pandemic
**** Subject to a phased review due to limited or no experience in EOIR
Source: https://www.oecd.org/tax/transparency/documents/schedule-of-reviews.pdf and
https://www.oecd.org/tax/transparency/documents/exchange-of-information-on-request-ratings.htm.

No African country is rated as Compliant on Element Most of the African countries are yet to be fully reviewed
A.1 due to deficiencies in the legal and regulatory in the second round of reviews. The Global Forum
framework for ensuring the availability of beneficial Secretariat, under the umbrella of the Africa Initiative,
ownership information and, in the case of combined will continue to work hand in hand with these countries
reviews, its implementation in practice. Only three to develop effective frameworks for beneficial ownership
African countries are rated Largely Compliant for this transparency. Similar support has been extended to
element (Mauritius, Morocco and Tunisia), while the countries that have been peer reviewed to close the gaps
remaining six are rated Partially Compliant (Botswana, identified during their review. This includes support to:
Ghana, Liberia, Nigeria, Seychelles, South Africa).
l raise awareness at the political level and within the
The key recommendations received by African countries legislative circles in the jurisdiction on the importance
are to ensure the definition of beneficial owner is in line of ensuring beneficial ownership transparency
with the standard and to issue adequate guidance on
l make a determination of the policy approach best
how to identify beneficial owners of legal entities and
suited for the jurisdiction when developing its
arrangements so that accurate, adequate and up-to date
beneficial ownership framework
information on beneficial owners is always available.
With respect to the practical implementation, the main l improve or introduce a definition of beneficial
recommendation is to ensure that adequate oversight owner in the domestic legal framework in line with
and enforcement activities are carried out. the standard, with corresponding guidance for the
TABLE 9. Determinations and ratings on availability of beneficial ownership information received by African
members (Element A.1)
African member country Legal framework determination Practical implementation rating

Botswana In Place but Needs Improvement Partially Compliant
Côte d’Ivoire In Place but Needs Improvement Not yet reviewed
Gabon In Place but Needs Improvement Not yet reviewed
Ghana In Place Partially Compliant
Kenya In Place but Needs Improvement Not yet reviewed
Liberia In Place Partially Compliant
Mauritius In Place but Needs Improvement Largely Compliant
Morocco In Place but Needs Improvement Largely Compliant
Nigeria In Place but Needs Improvement Partially Compliant
Seychelles In Place but Needs Improvement Partially Compliant
South Africa In Place but Needs Improvement Partially Compliant
Tanzania In Place but Needs Improvement Not yet reviewed
Togo In Place Not yet reviewed
Tunisia In Place Largely Compliant
Note: This table only takes into account both the nine African countries which have been fully reviewed by the Global Forum in the second round on EOIR peer reviews and
the five African countries that have only undergone a phase 1 review in the second round of EOIR peer reviews.
* Determinations are issued following an assessment of the legal and regulatory framework. The structure of the determinations is as follows, ranked in decreasing quality: In
Place, In Place But Needs Improvement and Not In Place.
** Ratings are issued following an assessment of the practical implementation of the legal and regulatory framework. The structure of the ratings is as follows, in decreasing
quality: On Track, Partially Compliant and Non-Compliant.
Source: Global Forum, EOIR peer reviews, https://www.oecd.org/tax/transparency/documents/exchange-of-information-on-request-ratings.htm.

identification of beneficial owners of different legal Impact of improvements in organisational processes

forms (e.g. partnerships) for managing exchange of information
l raise awareness amongst relevant stakeholders
The second round of EOIR peer reviews shows that
obliged with identifying, verifying and maintaining
African countries are taking steps to enhance their
the information on the identity of beneficial owners
organisational processes for managing EOI but some
within the jurisdiction
challenges remain.
l train relevant stakeholder on the various aspects of
beneficial ownership requirements The results of the peer reviews for the 9 African
countries that have been fully reviewed (Element C.5)12
l design effective supervision and enforcement
indicate that African countries should go beyond
activities to ensure compliance with the requirements
establishing EOI infrastructure to actually ensuring that
of the domestic legal framework.
they are implemented in an effective manner. While
two are rated Compliant with respect to Element C.5
12. No rating was assigned on Element C.5 for the five African countries that have only been subjected to a Phase 1 review as it involves issues of practice that are dealt with
in the Phase 2 review.
BOX 9. Financial Action Task Force: Updates to transparency and beneficial ownership requirements
The results of FATF Mutual Evaluations suggest that a “multi- l specification that information should be adequate for
pronged approach” is more effective than a single approach identifying the beneficial owner, accurate and based on
in ensuring beneficial ownership transparency. verification, and up to date.
Consequently, in March 2022 the FATF adopted a stronger With the implementation of the revised FATF standard
global beneficial ownership standard regarding legal worldwide, it is expected that more and more jurisdictions
persons, by revising Recommendation 24 and its Interpretive will take the multi-pronged approach, including a
Note. The main updates include: centralised register of beneficial owners to ensure
transparency of legal persons.
l explicit requirement for countries to use a “multi-
pronged approach” to ensure that adequate, accurate The revisions to Recommendation 24 also include stronger
and up-to-date information on the beneficial ownership controls to prevent the misuse of bearer shares and
of legal persons is available and can be accessed by the nominee arrangements.
competent authorities in a timely manner. The multi-
In March 2023, the FATF also updated its Recommendation
pronged approach requires as a minimum:
25 on transparency and beneficial ownership of legal
– a n entity approach (i.e. information held and/or arrangements to strengthen transparency of beneficial
supplied by legal persons themselves) ownership of legal arrangements. It particularly clarifies
that beneficial ownership requirements extend to both
– a central register approach (i.e. information held by public
the express trust and other similar legal arrangements and
authorities in a register) or an alternative mechanism if it
changes the “nexus” for triggering the
ensures rapid and efficient access to beneficial ownership
obligation of the trustee to obtain and
information for competent authorities
hold beneficial ownership information
– a ny other supplementary sources of information, as on the trust, which participates to better
necessary, commensurate to the risks faced by the transparency.
jurisdiction.
Note: Additional information can be found at FATF (2023), Guidance on Beneficial Ownership for Legal Persons, FATF, Paris,
https://www.fatf-gafi.org/content/fatf-gafi/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html.

FIGURE 10. Quality and timeliness of responses structures and effective systems to enable them handle
to requests for information (Element C.5): EOI requests efficiently. A functional EOI unit is also
Distribution of ratings for nine African countries key to spreading awareness amongst tax auditors and
investigators on the potential for EOI to assist them
1 obtain information necessary for cases with a cross-
(11%) 2 border element. Tools developed by the Global Forum
(22%) include the Model Manual on Exchange of Information
Compliant
for Tax Purposes (jointly developed with AfDB and the
Largely
World Bank Group)14 and the Toolkit for Establishing and
compliant
Running an Effective Exchange of Information Function
3 Partially
(33%) compliant (jointly developed with ATAF).15 The Global Forum
Secretariat will enhance its support for African countries
Non-
3 compliant to strengthen their EOI processes.
(34%)
IMPLEMENTATION OF THE STANDARD OF AUTOMATIC
EXCHANGE OF FINANCIAL ACCOUNT INFORMATION
Note: This figure is based on the ratings achieved by nine African members fully
reviewed in the second round of EOIR peer reviews (Mauritius, Morocco, Nigeria, In recognition of their unique challenges and the lower
Tunisia, South Africa, Botswana, Ghana, Liberia and Seychelles).
risk they pose to the level playing field, developing
Source: Global Forum, EOIR peer reviews, https://www.oecd.org/tax/transparency/
documents/exchange-of-information-on-request-ratings.htm. countries that do not host a financial centre were not
required to start AEOI by a defined date. Nonetheless, like
all members of the Global Forum, they are committed
and three are rated Largely Compliant, totaling 56%, the to implement the AEOI standard, albeit with a practical
remaining four (44%) obtained unsatisfactory ratings timeline, to be defined with the support of the Global
which included a Partially Compliant rating for three Forum Secretariat. Since the start of AEOI, the Secretariat
and a Non-Compliant rating for one (see Figure 10). has provided technical assistance to its members, focusing
on developing countries, to implement this standard.16
Although all the four African countries that received
a poor rating for “quality and timeliness of responses“ Increasing participation of Africa in automatic
(Element C.5)13 had established an EOI unit and exchange of financial account information
dedicated resources and tools for their proper
functioning, they all experienced delays in providing The technical assistance provided to African countries
information requested in a timely manner and failed has yielded positive results. The first automatic
to maintain effective communication channels with exchanges in Africa started in 2017 with two Africa
their EOI partners to update them of the progress Initiative members. Additional African countries joined
made in handling their requests. For some, the staffing the automatic exchanges each year in 2018, 2019 and
levels was found inadequate due to the large volume of 2020, bringing the total number of African members
EOI requests received. There is scope for improvements that had exchanged information automatically to
in the handling of EOI requests in these countries. five as of December 2022. These five members are
Since 2014, the Global Forum Secretariat has provided exchanging information reciprocally, i.e. they send
extensive technical assistance to the Africa Initiative and receive information, having successfully passed
members to establish efficient organisational their pre-exchange confidentiality and data safeguard
13. Element C.5 of the EOIR standard requires that jurisdictions should request and provide information under its network of agreements in an effective manner.
14. OECD, AfDB and WBG (2021), Model Manual for Exchange of Information for Tax Purposes, available at https://www.oecd.org/tax/transparency/documents/model-manual-
on-exchange-of-information-for-tax-purposes.htm. The toolkit is available in English, French, Portuguese, Spanish and Arabic.
15. OECD (2020), Toolkit for Establishing and Running an Effective Exchange of Information Function, available at
https://www.oecd.org/tax/transparency/documents/eoi-unit-toolkit.htm. The toolkit is available in English, French, Spanish and Arabic.
16. OECD (2021), Unleashing the potential of automatic exchange of information for developing countries (2021 Strategy),
https://www.oecd.org/tax/transparency/documents/aeoi-strategy-developing-countries.pdf.

Table 10. Status of African countries’ participation in automatic exchange of financial account information
Ghana
Kenya
Ghana Mauritius
Kenya Morocco
Ghana Mauritius Nigeria
Ghana Mauritius Nigeria Rwanda
Ghana Mauritius Nigeria Seychelles Seychelles
Mauritius Mauritius Nigeria Seychelles South Africa South Africa
Seychelles Seychelles Seychelles Seychelles South Africa Tunisia Tunisia
South Africa South Africa South Africa South Africa Uganda Uganda Uganda
2017 2018 2019 2020 2023 2024 2025

(Expected) (Expected) (Expected)
Source: Global Forum, Automatic Exchange of Information (AEOI): Status of Commitments https://www.oecd.org/tax/transparency/aeoi-commitments.pdf.
assessments which is a pre-requisite. In addition, five AEOI. The other challenges are delays in enacting
more African countries are committed to implementing legislation that translates the requirements of the CRS
AEOI within the next three years. These are Uganda into domestic law and putting in place a framework that
(2023), Kenya and Tunisia (2024) and Morocco and meets the requirements of the confidentiality and data
Rwanda (2025). Overall, it is expected that 10 African safeguards assessments (see right graph of Figure 12).
members will be exchanging information automatically The Global Forum Secretariat is equally supporting these
by 2025, as shown in Table 10. countries to put in place the essential building blocks for
AEOI, to develop administrative compliance strategies17
While commitment to AEOI is increasing, the full to assist countries in Module 7 of the modular approach
potential of this form of EOI is yet to be unlocked. for AEOI implementation (see Box 10) and to make
African countries that have not taken any step towards effective use of CRS data.
the implementation of AEOI indicated that the main
obstacles are the lack of an enabling domestic legal The Global Forum Secretariat remains committed to
framework and an international legal gateway for AEOI, providing African countries with technical assistance
an inadequate capacity and resources as well as the following the modular approach which has proven very
absence of a political decision to implement AEOI (see effective in enabling developing economies to determine
left graph of Figure 11). The Global Forum Secretariat a practicable date for their first exchanges.
is supporting two African countries to address
This includes, but is not limited to:
these challenges and commit to AEOI on a practical
timeframe. l the drafting or improvement of domestic legal
frameworks for AEOI
On the other hand, countries that are implementing
l onboarding the MAAC as the international legal
or are committed to automatic exchanges by a specific
gateway for AEOI
date indicated that the primary challenge is putting in
place an international legal framework that facilitates l signing and activating the CRS-MCAA18
17. OECD (2022), Model Administrative Compliance Strategy, available to tax authorities upon request.
18. To facilitate the large-scale implementation of the AEOI standard, the CRS-MCAA has been developed. A particular bilateral relationship under the CRS-MCAA becomes
effective only if both jurisdictions have the MAAC in effect, have filed the required notifications under Section 7 and have listed each other as exchange partner.
The text of the CRS-MCAA is available at
https://www.oecd.org/tax/automatic-exchange/international-framework-for-the-crs/multilateral-competent-authority-agreement.pdf.

FIGURE 11. Main challenges for African countries on the implementation of automatic exchange of financial
account information
Main challenges for African countries Main challenges for African countries
3 not implementing AEOI* in progress of implementing AEOI*
1 (5%)
(2%)
No political decision 2 Ratifying the MAAC
8 to implement AEOI
(14%) (9%) Commencing the
Not yet a signatory 3 7 confidentiality
to the MAAC (13%) (30%) (pre-exchange) assessment
17
(31%) Lack of capacity/ Putting in place primary
resources legislation
13
(24%) Lack of legal framework 3 Putting in place
(13%)
secondary legislation
Difficult to comply
with the confidentiality 3 Signing the CRS MCAA
requirements (13%)
5 Other
13
(24%) Other (22%)
Note: The figures are based on the responses of 38 African countries that responded to the Tax Transparency in Africa Survey 2023.
* AEOI stands for Automatic Exchange of Financial Account Information under the Common Reporting Standard.
l enrolment into the Common Transmission System (CTS)19 available to members. These include an e-learning
course on AEOI,20 a toolkit for the implementation of
l formulation and implementation of a strategy to
AEOI21 and a toolkit on confidentiality and information
ensure the effective compliance of financial institutions
security management.22 The tools provide detailed
with their due diligence and reporting obligations.
guidance and customisable solutions and share best
The technical assistance is supported by guidance and practices on various aspects of the implementation of
working tools developed by the Global Forum and the AEOI standard.
BOX 10. The Common Reporting Standard Model Administrative Compliance Strategy
The Model is directly linked to the requirements of the The Model intends to be: (i) explanatory, by providing
AEOI standard and ToR and illustrates the series of steps and comments to explain the context of each proposed section,
procedures that CAs should follow to ensure compliance (ii) flexible, by providing examples that jurisdictions may
from financial institutions in implementing their CRS due follow, and (iii) practical, by proposing text that jurisdictions
diligence and reporting rules. It outlines the key components could reproduce and/or adapt in their compliance
that a strategy for AEOI compliance should have and frameworks.
specific procedures to guide the implementation of each
The Model is available in English, French and Spanish to
component, such as procedures for identifying reporting
Global Forum member countries on demand.
financial institutions, risk assessment criteria to inform
compliance activities, and procedures to apply sanctions
when non-compliance is identified. Source: Global Forum Secretariat
19. KSP toolkit for the CTS, available at https://ksp-ta.org/#/elearning/elearning-detail/CFE1B4D4-E7A7-99EF-7D66670E76D77DB6.
20. Global Forum e-learning courses are available at: https://www.oecd.org/tax/transparency/resources/global-forum-e-learning.htm.
21. OECD (2021), Toolkit for the Implementation of the Standard for Automatic Exchange of Financial Account Information, https://www.oecd.org/tax/transparency/documents/
aeoi-implementation-toolkit_en.pdf.
22. OECD (2020), Confidentiality and Information Security Management Toolkit, https://www.oecd.org/tax/transparency/documents/confidentiality-ism-toolkit_en.pdf.

FIGURE 12. Number of activated automatic exchange relationships by African countries

90
80
79
75 75
72 73
Number of activated CRS-MCAA exchange relationships
70
60
by African members
50
40
30
20
10
0
Ghana Mauritius Nigeria Seychelles South Africa
Note: As of December 2022, the total number of CRS-MCAA signatories is 119.

Source: Automatic Exchange Portal, https://www.oecd.org/tax/automatic-exchange/international-framework-for-the-crs/exchange-relationships/.
Broad network of exchange partners rating of “In Place” while three “Need Improvement”.
Box 11 shows the steps taken by Mauritius to establish
The five African countries that have exchanged a legal framework that meets the requirements of the
information automatically have a broad network of AEOI standard and effectively implement it.
exchange partners under the CRS-MCAA, with a total of
374 AEOI relationships activated as at the end of 2022 The initial review of the effectiveness in practice of
(see Figure 12). It is expected that this figure will further AEOI also covered the three countries that exchanged
increase, with other countries in the region due to start information in 2017 and 2018 with varying results:
exchanging CRS data in the coming years (see Table 10). overall one country is “On Track”, one country is
“Partially Compliant”, while one country is “Non-
Outcome of the peer reviews on automatic exchange Compliant” (primarily due to malfunctioning of due
for African countries diligence and reporting procedures and a lack of
effective and timely exchange of information). Table 11
Part of the commitment to the AEOI standard includes shows the results of the review of the AEOI legal
being subject to the peer review process. The legal and frameworks and the initial review of effectiveness in
regulatory frameworks of the five African countries practice of AEOI in Africa.
that are exchanging information automatically have
been reviewed with mixed results. They all have an
international legal framework for AEOI as required by
the standard (In Place). However, not all of them have the
domestic legal framework required by the standard: in
three of these countries, the domestic legal framework “In
Place but Needs Improvements”. As a result, only two of
the five African countries received a satisfactory overall

TABLE 11. Results of peer reviews on automatic exchange of financial account information in Africa
Country Review of AEOI legal frameworks Initial review of effectiveness in practice of AEOI
CR1 CR2 Overall CR1 CR2 Overall rating

Domestic legal International determination Domestic International
framework legal framework information information
collection and exchange
reporting
Ghana In place In place In place

but needs but needs To be published in 2023
improvement improvement
Mauritius In place In place In place On track On track On track
Nigeria In place In place In place To be published in 2024

but needs but needs
Seychelles In place In place In place Non-compliant Non-compliant Non-compliant

but needs but needs
South Africa In place In place In place Partially On track Partially

compliant compliant
Note: *The structure of the determinations on the legal framework is as follows, ranked in decreasing quality: In Place, In Place But Needs Improvement and Not In Place.
**The structure of the ratings for effective implementation is as follows, in decreasing quality: On Track, Partially Compliant and Non-Compliant.
Source: OECD (2022), Peer Review of the Automatic Exchange of Financial Account Information 2022, https://doi.org/10.1787/36e7cded-en.
BOX 11. Implementation of automatic exchanges – the Mauritius experience
Mauritius became the third African country to exchange with regard to safeguarding the confidentiality
financial account information automatically under the CRS. of the data received. As a result, Mauritius’
It undertook its first AEOI exchanges in 2018, joining South confidentiality and data safeguard pre-exchange assessment
Africa and Seychelles, who had started in 2017 with the other was successful and it has been exchanging information on a
47 early adopter jurisdictions. reciprocal basis since 2018.
From the beginning, Mauritius took steps to ensure that it Since 2018, Mauritius has received and sent information on
has in place a legal and administrative framework that meets financial accounts as detailed in the table below.
the requirements of the international standard, including Continued...
Year Incoming Outgoing
No. of CRS Value of No. of CRS Value of

account reports No. of accounts received account reports No. of accounts sent
received Jurisdictions (in billion EUR) sent Jurisdictions (in billion EUR)
2018 51 984 49 18.5 30 770 66 27.8
2019 74 427 75 19.5 85 583 63 29.6
2020 86 358 78 30.1 230 176 71 32.1
2021 85 209 81 64 290 868 76 31.5
2022 96 599 83 47.4 307 898 75 33.1

Box 11 continued...
Mauritius has also taken appropriate steps to ensure the In 2022, Mauritius’ legal framework for implementing
effective implementation of the AEOI standard in practice. the AEOI standard was determined to be “In Place” and
consistent with the requirements of the AEOI ToR. This
This included:
includes Mauritius’ domestic legislative framework requiring
l establishing a dedicated unit to manage AEOI under reporting financial institutions to conduct the due diligence
the CRS and the Foreign Account Tax Compliance and reporting procedures and its international legal
Act (FATCA) and resourcing it with qualified staff and framework to exchange the information with all of Mauritius’
providing it with IT resources interested appropriate partners.
l intensive and continuous capacity building for officials In addition, in 2022, Mauritius’ implementation of the
of the Mauritius Revenue Authority (MRA) on the AEOI standard was determined to be “On Track” with
implementation of the AEOI standard respect to the requirements of the AEOI ToR to ensure the
effectiveness of the AEOI standard in practice. This includes
l developing an administrative compliance strategy
ensuring reporting financial institutions correctly conduct
including a programme for supervision and monitoring
the due diligence and reporting procedures and exchanging
of financial institutions with on-site visits conducted, to
the information in an effective and timely manner.
ensure that entities and accounts are classified properly,
that due diligence processes are applied in line with the Mauritius is also putting in place processes for making
standard and that proper reporting takes place. effective use of the information received, including matching
data received to the domestic database held by MRA.
To facilitate reporting, the MRA:
The data received has reinforced the risk-based selection
l has established a CRS Committee, which meets approach to identifying audit cases, which are referred
regularly. The CRS Committee consists of representatives to Fiscal Investigations Department for investigation for
of the Mauritius Revenue Authority, the State Law possible tax evasion. It has also led to the identification of
Office, the Ministry of Finance and Economic Planning persons who should have but did not file tax returns.
and Development and the Financial Sector. Its objective
CRS data has had a positive impact on tax compliance.
is to ensure the smooth implementation of the CRS
In addition to its deterrence value, MRA has identified
including identifying training requirements, guidelines
undisclosed income and raised assessments. Since 2018, the
and discussion on the technical aspects of the standard.
MRA has selected 972 cases for audit based on CRS data.
l has developed a CRS guidance with explanatory notes This has culminated in 44 assessments with additional tax
for the financial sector amounting to MUR 17 million (EUR 340 344) representing
MUR 114 million (EUR 2.3 million) of undisclosed income.
l regularly conducts workshops for the financial sector.
The workshops and training sessions provided to The implementation of AEOI in Mauritius has benefitted the
the financial sector was primarily directed to the country in the following ways:
understanding and implementation of the technical
l It has enabled the MRA to have better visibility on
aspects of CRS. The topics covered included the
the wealth/foreign assets held abroad by residents of
requirements for the identification of Financial
Mauritius and helped in detecting possible tax evasion
Institutions, Reportable Persons and information to be
reported, as well as the common due diligence rules. l It has enabled MRA to identify additional revenue.
The Mauritius Revenue Authority supplemented these
l It has consolidated the position of Mauritius as a sound
trainings with sessions on their platform to be used by
and regulated financial center, which complies with all
Financial Institutions to report information collected
international standards and requirements.
and the use of the XML Schema.
The steps taken by Mauritius have yielded positive results Source: Mauritius Revenue Authority.
in the AEOI peer reviews.

Section head
Using tax transparency

for domestic resource
mobilisation
4 The tax transparency standards aim to ensure an effective
exchange of information among tax authorities around the world,
for the enforcement of their tax laws and to better tackle cross-
border tax evasion and increase domestic resource mobilisation.

Using tax transparency for domestic resource mobilisation
2022
KEY TAKE-AWAYS
Use of the tax transparency standards by African countries
l African countries made a total of 531 EOI requests in 2022. l Since 2016, EOI between African countries has been
Although this represents a decline from the 592 requests increasing. In 2022, 21% (79) of the requests received and
made in 2021, the gap between requests made and received 27% (126) of the requests sent were received from or sent to
is narrower than pre-COVID-19 pandemic levels. other African country respectively. With the entry into force
of the Africa Free Continental Trade Area Agreement, intra-
l The number of African countries making requests rose to 19 African EOI will play a key role in enabling African countries
in 2022, from 15 in 2021. However, 7 countries account for to curb potential intra-Africa cross-border tax evasion due to
92% of all requests sent. increased intra-African trade.
l The number of incoming EOI requests rose 9% to 683 in l In 2022, 2 African countries (Nigeria and South Africa)
2022, from 628 in 2021. A total of 19 African countries have reported making follow-up EOI requests based on
received EOI requests in 2022, compared to 18 in 2021. information received and sent under AEOI.
Eight countries received 90% of all incoming requests.
USE OF EXCHANGE OF INFORMATION ON REQUEST BY AFRICAN COUNTRIES
EOIR is a powerful tool for detecting tax evasion, for relevant information to other jurisdictions and to use
provided that it is actively used by tax administrations. such information for their tax audits and investigations
Tax auditors are strongly encouraged to make requests (see Box 12).
12th meeting of
8 November 2022,
Seville, Spain.

11th meeting of
14-16 June 2022,
Nairobi, Kenya.
BOX 12. South Africa: Case studies on the usefulness of exchange of information on request
CASE 1: Exchange of information as tool for detecting received by entities within their jurisdictions.
tax fraud in indirect taxes The identified transactions related to exports
via sea and no other sources were domestically available to
The South African Revenue Service (SARS) launched a
confirm the validity of the transactions.
Value Added Tax (VAT) audit covering the period August
2014 to March 2016, based on the significant VAT refund South Africa has EOI instruments with all the six jurisdictions
claims made by a taxpayer (W). W also had a history of from which a confirmation was required. The SARS
non-compliance and had been subject to a VAT and Income delegated Competent Authority used the available legal
Tax audit in 2011 covering the financial years 2003 to 2009. instruments to request the relevant treaty partners to
In response to audit queries, W submitted that the refund confirm that the importers were registered businesses
returns were as a result zero-rated exports to foreign within their jurisdictions and to authenticate the customs
jurisdictions for which W had paid VAT. documents declared at the South African border posts. SARS
attached the customs documentation for the identified
The VAT Audit Team used all domestically available resources
transactions to each of the six requests. SARS also requested
to verify that the exports by W had met all the requirements
the annual financial statements of the importers for the
and followed requisite procedures for the exportation
relevant financial years to enable the VAT Audit Team to
of goods from South Africa to foreign jurisdictions as
check whether the transactions were reflected.
prescribed in domestic legislation. Only a few anomalies
were identified majorly relating to a limited number of older The six treaty partners submitted partial responses with
export transactions for which no export documentation the last response received within nine months of the first
could be provided. However, to confirm with certainty that request. As a result of the responses received, the VAT
all exports for which W had claimed a refund on qualified for Audit Team issued additional assessments to taxpayer (W)
VAT zero rate and that W was compliant and not conducting to the value of ZAR 71.56 million (EUR 3.44 million) which
any fraudulent activities, the VAT Audit Team submitted included principal tax of ZAR 32.6 million (EUR 1.6 million)
a request to the EOI Unit to send a request to a sample of and penalties for understating tax payable of ZAR 39 million
six recipient jurisdictions that the goods had indeed been (EUR 1.9 million).

Box 12 continued...
CASE 2: Exchange of information used to resolve a Thanks to information received, SARS auditors collected
fraudulent value added tax refund claim ZAR 681.8 million (EUR 32.8 million) additional assessments,
which included principal tax of ZAR 272.7 million
A South African entity (Z) traded in gold jewellery.
(EUR 13.1 million) and penalty for understating tax payable
Documentary proof supplied by Z during an audit revealed
of ZAR 409.1 million (EUR 19.7 million).
that it purchased gold jewellery from three South African
suppliers, and exported approximately 6 300 kgs of gold
Lessons learnt
jewellery to another entity (X) in jurisdiction Y between
December 2016 and September 2019. Based on the VAT Act, The key lessons learnt by the SARS in the two cases is that
the export of the gold is regarded as a zero-rated supply. EOI could be as useful for indirect taxes as it is for direct
Therefore, a taxpayer who buys gold from the domestic market taxes. It is therefore important to have an EOI instrument,
and sells it outside South Africa can claim a refund from such as the MAAC, that facilities EOI for both direct and
SARS for the 15% VAT paid when purchasing the gold from indirect taxes. In addition, SARS learnt that it is important
local suppliers (input VAT). The SARS audit team suspected to be specific about the information required to finalise
that Z made false exports in order to claim VAT refunds from the audit as this enables the requested jurisdiction to
SARS but sold the gold to local refineries in South Africa. rapidly respond to the request without seeking additional
clarification, therefore saving on time. Moreover, it is equally
In order for SARS to authenticate the transaction, confirming
important for the auditors to demonstrate that they have
the existence of the customer in the partner jurisdiction
exhausted all domestically available resources before
was vital. The Audit Team performed a search on whether X
submitting an EOI request. This includes checking publicly
existed in jurisdiction Y using publicly available information.
available information in the other jurisdiction. Finally, one
However, the search revealed that there were entities with
of these cases showed the importance of having a wide
similar names, but there was no exact match.
network of EOI relationships with other countries which
SARS sent a request to jurisdiction Y to confirm whether X enable SARS to send requests and receive information
was legitimate registered entity and, if so, the nature of the from six jurisdictions regarding the operations of a single
business it conducted and whether it traded during the taxpayer. Had there been no legal instrument in place the
period under investigation. Jurisdiction Y responded within audit would have been abandoned.
120 days indicating that, while the entity was registered, it
did not trade during the period under investigation. Source: The South African Revenue Service

FIGURE 13. Requests for information sent and received by African countries since 2014
800
Total number of EOI requests received Total number of EOI requests sent
700 683
628
609
585
600
569
592 531
502
Number of EOI requests
500 469
421
451
400
381
300
279
198
200 218
109
100
38 67
0
2014 2015 2016 2017 2018 2019 2020 2021 2022
Note: This graph reflects the situation for 38 African countries that responded to the Tax Transparency in Africa Survey 2023.
Figure 13 shows that the 38 African countries that In contrast, the number of incoming EOI requests rose
responded to the survey made a total of 531 EOI requests 9% to 683 in 2022 from 628 in 2021 (see Figure 13). A
in 2022 compared to 592 requests made in 2021. total of 19 African countries received EOI requests in
Although African countries became net senders for the 2022, compared to 18 in 2021. Eight countries (Algeria,
first time in 2020, they received more requests than Kenya, Mauritius, Morocco, Senegal, Seychelles,
they sent in 2022 and 2021. However, the gap between South Africa and Tunisia) received 90% of all incoming
requests sent and received is narrower than the pre- requests with Mauritius and Morocco accounting for
COVID-19 pandemic levels. Nonetheless, this highlights more than 50% of all requests received.
the need for continuous efforts to make tax auditors and
investigators aware of the benefits of using EOI in cases Compared to 2021, the gap between the EOI requests
with a cross-border element. It is also of paramount received and made by African countries has expanded
importance for the senior management of tax authorities further to 152 requests in 2022, but remains lower
across the continent to put EOI high on their strategy to than the average gap observed for 2014-2019, which
tackle tax evasion. stood at 241. While this clearly shows that most of
the African countries still receive more requests than
While the total number of EOI requests slightly they make, seven countries (Kenya, Nigeria, Rwanda,
decreased, the number of African countries making Seychelles, South Africa, Tunisia and Uganda) were net
requests rose to 19 in 2022 from 15 in 2021. However, senders of requests, having sent more requests than
four countries (Kenya, Nigeria, South Africa and Tunisia) they received in 2022, compared to six net senders in
accounted for 86% of all requests sent in 2022. Of these 2021. This emphasises the need for increased use of the
four, Kenya (28%) and Tunisia (47%) accounted for over EOI infrastructures by African countries.
75% of all requests sent. Out of 16 countries, 12 made
between 1 and 10 requests and 4 made more than Since 2016, EOI between African countries has been
20 requests. Out of the 4 countries that sent more than increasing. In 2022, 21% of the requests received and
20 requests, only 2 sent more than 100 requests. 27% of the requests sent were received from or sent to

FIGURE 14. Number of African countries sending requests for information

20
19 19
1 to 10 requests 11 to 20 requests More than 20 requests
18
Countries making requests
16
15 15 15
14 14
14
12 13
12
11 11
10
10
9 9 9
8
8
6
6
5
4 4 4
4
3 3
2 2 2 2
2
1 1 1 1 1 1
0
2014 2015 2016 2017 2018 2019 2020 2021 2022
Note: The graph reflects the situation of 38 African countries which provided data.
other African countries respectively. This shows that indicator of the quality of the information received,
more and more African countries have been designated i.e. the higher the matching rates, the more information
as one of the top five EOI partners for both incoming could be used to detect possible non-compliance with
and outgoing EOI requests. Within the last two years, the tax obligations of taxpayers. The CRS data matching
African countries have mainly been receiving requests rate has significantly improved over the years, to reach
from Côte d’Ivoire, Mauritius, and South Africa. As for 70% worldwide in 2021.1
the main intra-regional partners for outgoing requests,
Mauritius and South Africa are the countries that other AEOI is complementary to EOIR. The process of
African countries are most interested in receiving matching received information to domestic taxpayer
information from. The increasing intra-African EOI details is fundamental to fully realise the benefits of
is a positive trend that should be encouraged as it the AEOI standard. Once the information received is
demonstrates that EOI is an effective tool to tackle tax processed, receiving jurisdictions can use it for tax
evasion from outside and from within the continent. compliance purposes and make specific follow-up
This is a safeguard to the risk of increased tax evasion requests under the EOIR standard for open tax inquiries.
in the context of AfCFTA. In 2022, Nigeria and South Africa reported making follow
up EOIR requests based on CRS data.
USE OF AUTOMATIC EXCHANGE OF INFORMATION BY
AFRICAN COUNTRIES The AEOI standard has a powerful deterrent effect, as
residents of a country know that information on their
To effectively use CRS data, residence countries financial assets and income in other jurisdictions will
receiving information need to match it to their be collected and shared, on an automatic basis, with
taxpayers’ declarations maintained in their domestic the tax administration of their country of residence.
databases. Matching rates can therefore serve as an Therefore, many jurisdictions have taken advantage
1. OECD (2020), Tax Transparency in Africa 2020: Africa Initiative Progress Report, https://www.oecd.org/tax/transparency/documents/tax-transparency-in-africa-2020.pdf.

FIGURE 15. Evolution of top-five African exchange partners of African countries

40%
37% Intra-African incoming requests Intra-African outgoing requests
35%
% of top intra-regional exchange partners
30%
27%
25%
25% 24% 24%
25% 25%
23% 22%
20%
15%
15% 15%
13%
10%
10% 10%
5%
0%
2016 2017 2018 2019 2020 2021 2022
Note: This graph reflects the situation of 38 African countries who responded to the Tax Transparency in Africa Survey 2023. Please note that the number of African countries
participating in the survey has significantly increased over years and therefore the sample size varies across years.
of the implementation of the AEOI standard to launch

VDPs prior to their first automatic exchanges, to 12th meeting of
encourage residents to self-declare financial assets
8 November 2022,
and income held in other jurisdictions and, most Seville, Spain.
importantly, to pay any related taxes due. As presented
in previous sections of this report, the results of the
AEOI-related VDPs account for a significant proportion
of the EUR 114 billion in tax revenue identified by tax
administrations worldwide since the move to AEOI.
Of the ten African countries committed to AEOI with

a date for their first exchanges, only South Africa and
Nigeria have used a VDPs prior to their first automatic
exchanges.2 The remaining seven countries have
not made use of VDPs prior to their first automatic
exchanges, representing a missed opportunity to take
advantage of the deterrent effect of AEOI to enhance
voluntary compliance, expand their tax base and collect
additional revenue. All African countries committing to
start AEOI exchanges by a specific date are encouraged
to consider the potential benefits of VDPs prior to their
first exchanges.
2. Ibid

Section head
Looking ahead
5 Since 2014, the tax transparency agenda has greatly advanced
in Africa. More remains to be done to ensure the effective
implementation of, and benefits from, the standards of
transparency and exchange of information in African countries’
domestic resource mobilisation efforts.
AFRICA2023
2023
Looking ahead
MAKING A RADICAL CHANGE IN THE USE OF THE STRENGTHENING AFRICAN TAX AUTHORITIES’
EXCHANGE OF INFORMATION ON REQUEST CAPACITIES TO BENEFIT FROM TAX TRANSPARENCY
AND EXCHANGE OF INFORMATION
Only a limited number of African countries are actively
using their EOI infrastructures to make requests for Knowledgeable and skilled human resources are
information for use in tax audits/investigations with a key to benefitting from the implementation of the
cross-border elements. During 2023, the Africa Initiative tax transparency standards. Enhancing the skills of
will focus on supporting African countries’ efforts tax officials on the use of the tax transparency and
to consolidate their EOI infrastructures, to develop EOI tools in their daily activities is a critical step towards
strategies, and high-level management commitments to optimising EOI in DRM.
promote and incentivise the use of EOI and to track of
its impact on DRM. The Global Forum Secretariat and its partners will
continue to organise training events, in different
UNPACKING THE BENEFIT OF AUTOMATIC EXCHANGE formats, to develop skills in all relevant areas of tax
OF FINANCIAL ACCOUNT INFORMATION FOR MORE transparency. This includes equipping local tax officials
AFRICAN COUNTRIES as EOI champions and change agents through the
Train the Trainer programme, as well as promoting
African countries are still far from unpacking the full gender balance through the Women Leaders in
benefits of AEOI, as only a limited number is exchanging Tax Transparency programme. African countries’
information automatically under the CRS with other participation in the ISM network will also be promoted.
jurisdictions. During 2023, more African countries will Moreover, new targeted training and capacity-building
thus be encouraged to consider participating in AEOI. initiatives will be considered to enhance the use of
The Africa Initiative will continue raising awareness on EOIR requests in African tax administrations during
the potential of AEOI, building knowledge and providing their audit and investigation processes.
technical support to help interested African countries to
put in place the building blocks essential for AEOI. ADVANCING THE USE OF CROSS-BORDER ASSISTANCE
IN THE RECOVERY OF TAX CLAIMS
African countries, which are already exchanging
information automatically, will continue receiving In 2023, the Global Forum Secretariat will continue
tailored technical assistance to develop and effectively to build capacities on cross-border assistance in
implement a sound compliance strategy to ensure that the recovery of tax claims in Africa with a focus on
financial institutions comply with their CRS obligations, the essential building blocks necessary for effective
to prepare for AEOI peer reviews and to address any participation in this form of international co-operation.
gaps identified in the context of the peer review process. Regional workshops will be held in collaboration with
Finally, African countries will receive support on the partner organisations, such as ATAF and CREDAF.
effective use of CRS data to help them fully realise the
benefits of AEOI. The Global Forum Secretariat will also develop guidance
and practical tools to be used by countries interested in
putting in place an enabling domestic and international
legal framework, as well as establishing operational
frameworks for cross-border assistance in the recovery
of tax claims, complemented by tailored assistance to
interested countries.

6 Annex
Summary of the tax transparency progress by country in 2022
Implementation of EOIR standard EOI infrastructure
Technical
assistance 1st 2nd CA EOI EOI resources
Country Membership programme round round delegation Unit and tools
Induction
Algeria 2021 – – Yes Yes In progress
programme
Induction
Angola* 2023 – – Yes Yes In progress
programme-
Induction Preparation in progress

Benin 2017 – In progress In progress In progress
programme Review in Q4 2023
PC in 2019
Botswana 2011 A la carte LC (2016) Work in progress to address Yes No Yes
the deficiencies
Preparation in progress
Burkina Faso 2012 A la carte LC (2016) Yes Yes Yes
Review in Q4 2023

Cabo Verde 2018 – Yes Yes Yes
Cameroon 2012 A la carte LC (2016) Review launched in Q1 2023 Yes Yes Yes
Induction No action taken

Chad 2016 – No No Yes
Congo Induction
2022 – - Yes No No
(Rep. of the) programme
Induction Phase 1 in 2021 Phase 2

Côte d’Ivoire 2016 – Yes Yes Yes
programme in Q4 2023

Djibouti 2017 – - - -
Induction
Egypt 2016 – Launched in Q4 2022 Yes Yes Yes
programme

Eswatini 2018 – Yes In progress Yes
Phase 1 in 2022
Gabon 2012 A la carte LC in 2016 Yes Yes Yes
Phase 2 in Q1 2025
PC in 2018-
Ghana 2011 A la carte LC in 2014 Work in progress to address Yes Yes Yes
the deficiencies
Induction
Guinea 2019 – Review in Q3 2024 No No No
programme

Annex
Effective use of EOI

EOI network over the last 3 years
AEOI standard
and MAAC status
None
Very narrow <10 Low <10;
Narrow <50 Medium <50 Revenue Confidentiality and
Wide <100 High <100 gains data safeguards AEOI
Very wide >100 EOI strategy Very High >100 identified framework commitment
Narrow - Low No No action No
Very narrow
- None No No action No
Invited to sign in 2022
Very wide
In progress None No No action No
Deposited ratification instrument in 2023
Very wide
MAAC in force since 2021
Narrow
In progress Low Yes No action No
Deposited ratification instrument in 2022
Very wide
Technical assistance
Very wide
Yes Medium Yes – preliminary No
assessment in 2019
Very narrow
No None No No action No
MAAC initiated in 2017
Very narrow
MAAC process not initiated
Narrow
MAC process not initiated
Very narrow
- - - No action No
Wide
- - - No action Pilot project with UK
MAAC process initiated in 2022
Very wide
No Low No No action No
Very narrow
MAC Ratified in 2016 No None No No action No
but not yet deposited
Very wide Re-assessment

In progress Low No First exchange in 2019
MAAC in force since 2013 scheduled in 2020
Very narrow

Annex
Technical
Guinea-Bissau Non member – – – No No No
Phase 1 in 2021
Kenya 2010 A la carte LC in 2016 Yes Yes Yes
Phase 2 launched in Q4 2022
Lesotho 2013 A la carte LC in 2016 Phase 1 launched in Q2 2022 Yes Yes Yes
Legal
PC in 2020
framework
Liberia 2009 A la carte Work in progress to address the Yes Yes Yes
appropriate
deficiencies
in 2016

Madagascar 2017 – Yes No No
Malawi Non-Member – – – No No No

Mali 2020 – No No No
Mauritania 2012 A la carte LC in 2016 Review launched in Q1 2023 Yes Yes In progress
Mauritius 2009 A la carte LC in 2014 C in 2017 Yes Yes Yes
Morocco 2011 A la carte LC in 2016 LC in 2022 Yes Yes Yes
Induction Preparation to be launched

Namibia 2019 – No Yes No
programme Q3 2024

Niger 2015 – Yes No No
Nigeria 2011 A la carte LC in 2016 LC in 2023 Yes Yes Yes

Rwanda 2017 – Yes Yes Yes
Senegal 2012 A la carte LC in 2016 Yes Yes Yes
Review in Q3 2023
Seychelles 2009 A la carte LC in 2016 PC in 2020 Yes Yes Yes

Annex

AEOI standard
and MAAC status
None
Very narrow
Very wide Technical assistance on First exchange intended

Yes Very High Yes
MAAC in force since 2020 going in 2024
Very narrow
MAAC initiated in 2017
Very wide
No Low No – preliminary No
assessment in 2018
Very narrow
Signed MAAC in 2022 but not yet No None No No action No
deposited
Very narrow
Narrow
Very wide
Very wide
No Medium No Successfully assessed First exchange in 2018
Technical assistance First exchange intended

Very wide
In progress Medium No – preliminary in 2023
assessment on going
Very wide
Very narrow
Very wide
In progress Very High No – preliminary First exchanges in 2020
assessment in 2020
Very wide First exchanges
No Low No – preliminary
MAAC in force since 2022 intended in 2025
assessment started
Very wide
No Medium Yes – preliminary Under consideration
assessment started
Very wide
No Medium No Successfully assessed First exchanges in 2017

Annex
Technical
2023
Sierra Leone* – – Not yet scheduled Yes No No
South Africa 2009 A la carte C in 2013 LC in 2022 Yes Yes Yes
Induction Phase 1 in 2021

Tanzania 2015 – No Yes Yes
programme Phase 2 in Q3 2024
Gambia Non-member – – – Yes No No
Induction Phase 1 in 2023

Togo 2016 - In progress Yes Yes
programme Phase 2 in Q3 2026
Legal
framework
Tunisia 2012 A la carte LC in 2020 Yes Yes Yes
appropriate
in 2016
Uganda 2012 A la carte LC in 2016 Yes Yes Yes
Review in Q2 2023
Zambia Non-member – – – No No No
Induction
Zimbabwe* 2023 – Not yet scheduled No No No
programme
* These countries joined the Global Forum in 2023. The table therefore does not reflect any progress made in respect to them in 2022.

Annex

AEOI standard
and MAAC status
None
Very narrow
Very wide
Yes High Yes Successfully assessed First exchanges in 2017
Very narrow
In progress Low No No action No
Very narrow
Narrow
In progress None Yes No action No
MAAC signed in 2020
Yes Very high Yes – preliminary
assessment started
Yes High Yes – preliminary
assessment started
Very narrow
Very narrow
© OECD 2023
This work is published under the responsibility of the Secretary-General of the OECD. The opinions expressed and arguments employed
herein do not necessarily reflect the official views of OECD member countries or of members of the Global Forum on Transparency and
Exchange of Information for Tax Purposes.
This document, as well as any data and map included herein, are without prejudice to the status of or sovereignty over any territory, to
the delimitation of international frontiers and boundaries and to the name of any territory, city or area.

For more information:
www.au.int
AUC-ETIM@africa-union.org
@_AfricanUnion
www.ataftax.org
@ATAFtax
www.oecd.org/tax/transparency
gftaxcooperation@oecd.org
@OECDtax | #TaxTransparency
OECD Tax

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Tax Transparency in Africa 2023

Africa Initiative Progress Report

The Africa Initiative, its members and partners

2 | TAX TRANSPARENCY IN AFRICA 2023

The 34 signatories of the Yaoundé Declaration, as of 31 December 2022

Liberia Madagascar Mali Mauritania Mauritius Morocco Niger Nigeria Rwanda

TAX TRANSPARENCY IN AFRICA 2023 | 3

The “core stage” encompasses: l increase in the number of African countries

Members of the Africa Initiative

Kenya Lesotho Liberia Madagascar Mali Mauritania Mauritius Morocco

Tanzania Togo Tunisia Uganda Zimbabwe

More information on the Africa Initiative is available at: https://oe.cd/africa-initiative.

4 | TAX TRANSPARENCY IN AFRICA 2023

Leadership of the Africa Initiative since 2021

CHAIR VICE-CHAIR CO-CHAIR CO-CHAIR

Partners and donors of the Africa Initiative

Federal Department of Economic Affairs,

African Tax Co-funded by the

African Union West African Tax

TAX TRANSPARENCY IN AFRICA 2023 | 5

6 | TAX TRANSPARENCY IN AFRICA 2023

The Africa Initiative is a concrete and impactful

TAX TRANSPARENCY IN AFRICA 2023 | 7

8 | TAX TRANSPARENCY IN AFRICA 2023

Edward Kieswetter Dr Philippe Kokou Tchodie Zayda Manatta Logan Wort

TAX TRANSPARENCY IN AFRICA 2023 | 9

10 | TAX TRANSPARENCY IN AFRICA 2023

2. DEVELOPMENTS IN TAX TRANSPARENCY

Summary of the tax transparency progress by country

Please cite this report as:

TAX TRANSPARENCY IN AFRICA 2023 | 11

Abbreviations and acronyms

12 | TAX TRANSPARENCY IN AFRICA 2023

In 2022, the Africa Initiative redoubled its efforts to drum up political

The high-level engagements contributed to

14 | TAX TRANSPARENCY IN AFRICA 2023

include continued capacity-building and awareness- received pre-membership support to implement an

TAX TRANSPARENCY IN AFRICA 2023 | 15

37 Members of the Africa initiative Capacity building in figures in Africa in 2022

Implementation of exchange of information in Africa in 2022

16 | TAX TRANSPARENCY IN AFRICA 2023

Number of countries with the MAAC in force

(23%) South Africa

Revenue identified in 2022 Total since 2009

The critical role of

6. UNCTAD (2022), Report on Illicit Financial Flows in Africa. https://unctad.org/system/files/non-official-document/IFFsAfrica_FinalReport_20221121.pdf.

TAX TRANSPARENCY IN AFRICA 2023 | 19

obstacle to international development efforts and Transparency and Exchange of Information on

11. AU Commission (2015). Agenda 2063: The Africa we want, https://au.int/sites/default/files/documents/36204-doc-agenda2063_popular_version_en.pdf.

20 | TAX TRANSPARENCY IN AFRICA 2023

TABLE 1. Overview of the tax transparency standards

TAX TRANSPARENCY IN AFRICA 2023 | 21

FIGURE 1. Revenues identified as a result of exchange of information, in EUR million

22 | TAX TRANSPARENCY IN AFRICA 2023

Number of financial accounts (in million)

TAX TRANSPARENCY IN AFRICA 2023 | 23

TAX TRANSPARENCY IN AFRICA 2023 | 25

26 | TAX TRANSPARENCY IN AFRICA 2023