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Obstacles to progress


                                                                                                   Realities

                  as manufacturing. Neither is such investment the result of corporate tax incentives but rather

                  the existence of natural resources, namely oil and gas.
                                                           ***
                  The use of corporate tax incentives is causing a competitive race to the bottom among
                  countries in West Africa which is detrimental to national revenue bases and regional

                  integration. “
                                 "The West African Giveaway: Use & Abuse of Corporate Tax Incentives in ECOWAS."   208
                                                                               Tax Justice Network & Action Aid
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            Tax Havens
                  “ In 2013, the Africa Progress Panel, chaired by Kofi Annan, and Global Witness examined five

                  major sales of mining rights in DRC. Each deal involved firms registered in the British Virgin
                  Islands. We estimated the gap between the market value of the concessions and the price paid
                  was at least $1.36 billion – almost double what the DRC spends each year on health and

                  education combined. “
                                        "Africa Is Rich in Resources – but Tax Havens Are Keeping Its People Poor."   209
                                                                                       World Economic Forum.
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            Tax Treaties
                  “ Tax treaties are agreements through which two countries agree to assign and restrict taxing

                  rights on economic activities that span both countries. They were traditionally concluded
                  mainly to avoid double taxation and create a favourable investment climate.

                  However, in recent years, tax treaties concluded by sub-Saharan African countries – with OECD
                  countries in particular – have often resulted in them slowly ceding their taxing rights over

                  income earned within their jurisdiction. “
                                                  "Review of Tax Treaty Practices and Policy Framework in Africa"   210
                                                              ICTD Working Paper 102 by Catherine Ngina Mutava

                                                          *****
                  “ There are almost 300 tax treaties in force in Sub-Saharan Africa countries. About half of them are

                  with Western European countries, chiefly with former colonial powers and Nordic countries.
                  Tax treaties reflect the political, legal and economic environments of the time at which they were
                  concluded. This includes colonial relations, the fashion for 'tax sparing credits', and the era before

                  recent developments in tax information exchange.
                  Over time, treaties signed by African countries have capped the rates of withholding taxes (WHTs)
                  that they can apply at lower and lower rates. Although this partly reflects a fall in statutory WHT

                  rates in some countries, Zambia is an example of a country where the revenue that can be raised by
                  from recent increases in statutory WHTs will be limited by the limits imposed in its treaties.
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