African and OECD TP updates: September 2025
A round-up of transfer pricing and related updates from around the African continent and beyond.
(Sources: reports issued by organisations, government documents and legislation (where available) or other tax news platforms, such as Orbitax, MNETax, etc.)
OECD and G20 updates
GloBE information return (pillar two) – status message XML schema (user guide)
The OECD released a user guide for tax administrations on the GloBE Information Return (GIR) Status Message XML Schema. It explains how competent authorities can report file-level and record-level errors back to the sender after automatic exchanges. Read more here.
OECD secretary-general tax report to the G20 finance ministers and central bank governors
Ahead of the 17–18 July meetings in Durban, the OECD provided a comprehensive update on international tax co-operation priorities, including BEPS implementation, simplification work under the Two-Pillar solution, and tax transparency.
Following the meetings, finance ministers and central bank governors agreed to continue engaging constructively to address concerns regarding Pillar Two global minimum taxes (including issues around substance-based incentives and level playing field), alongside broader tax transparency and capacity-building work.
Consultation: transfer pricing framework for copper
The OECD/IGF launched a consultation applying the “Determining the Price of Minerals” framework to copper. Submissions close on 17 September. Read more.
Tax co-operation for development: progress report on 2024
The OECD reports rising demand from developing countries for tax support, expanded training and bilateral programmes (including Tax Inspectors Without Borders), and measurable revenue impacts from transparency initiatives.
Additional OECD news
- Tax Inspectors Without Borders (TIWB) expansion plan announced at FFD4
- Steel Outlook 2025 press release
- Global Drought Outlook (economic risks)
- OECD Economic Outlook 2025-1
- Supply Chain Resilience Review
- OECD beta AI capability indicators
- Blog post: SMEs and trade disruption
The Kenya Revenue Authority set the market interest rate and deemed interest rate at 8% for July to September 2025 and prescribed the low-interest (loan) benefit rate at 9% for July to December 2025. KRA’s notice also reiterates the computation mechanics for fringe benefit tax and deemed interest.
Key highlights:
- Market/deemed rate: 8% (Jul – Sep 2025).
- Low-interest benefit rate: 9% (Jul – Dec 2025).
- Deemed interest subject to withholding tax under Kenyan law.
South Africa
SARS updated Table 3 (rates at which interest-free or low-interest loans are subject to income tax) to reflect an official rate of 8.00% with effect from 1 September 2025, following the South African Reserve Bank repo rate cut on 31 July 2025. This rate determines the taxable fringe benefit where employee/director loans are priced below the official rate. View the table here.
Tanzania
The Finance Act, 2025 (enacted 30 June 2025) introduces several measures relevant to corporate tax and transfer pricing. Key items include:
VAT measures, including a reduced 16% VAT on certain B2C online payments from 1 September 2025, and VAT withholding by designated agents (3% on goods; 6% on services).
An amendment to the definition of equity to (re)include positive retained earnings for thin capitalisation purposes.
A 10% withholding tax on 30% of retained earnings that remain undistributed after 12 months (treated as a deemed distribution).
An increase in the Alternative Minimum Tax to 1% for companies with losses in three consecutive years.
A new transfer pricing penalty for loss-making companies equal to 30% of the adjusted overstated loss where the arm’s-length principle is not applied (the existing penalty for profit-making companies remains 100% of the tax shortfall).
Increased withholding tax to 10% on insurance/reinsurance premiums paid to non-residents and on professional/management services in the extractives sector.
Sector-specific changes to loss carry-forward limits in mining, petroleum, oil and gas (from 70% to 60% of current-year profits).
