NG Incentives in Africa PDF

Investing in
Africa
A guide to tax / incentives in Africa
Contents
Overview 3
Southern Africa
— Angola 5
— Botswana 7
— Malawi 8
— Mozambique 9
— Namibia 11
— South Africa 12
— Swaziland 15
— Zambia 16
— Zimbabwe 17
Eastern Africa
— Burundi 19
— Ethiopia 20
— Kenya 21
— Mauritius 23
— Rwanda 24
— Somaliland 27
— South Sudan 28
— Tanzania 29
— Uganda 30
Central Africa Western Africa

— Chad 36 — Cameroon 52
— Democratic Republic of Congo 37 — Ghana 53
— Republic of Congo 40 — Ivory Coast 55
— São Tomé and Príncipe 41 — Liberia 57
— Nigeria 59
Northern Africa
— Sierra Leone
— Egypt 46
— Libya 47
— Morocco 48
— Tunisia 49
Investing in Africa – A Guide to Tax / Incentives in Africa 2

Overview – Investing in Africa
Introduction
The purpose of this guideline is to build a greater understanding the landscape of incentives offered by African
countries, both to local and foreign investors. Based on the 2017 IMF Data Mapper, there has been a 4.6%
change in the Real GDP growth rate for emerging markets and developing economies.
According to the World Bank Group Doing Business 2017 report, Mauritius is the top-performing African
country (ranked 49 out of 190 total countries). The continent has seen great improvements, for example the
average number of days needed to start a business dropped from 37 to 27 in five years. The continent is also
the second-highest adopter of reforms, behind Europe and Central Asia. Some examples of said reforms
include introducing and improving data portals in Nigeria, Rwanda, and South Africa. For a second consecutive
year, Kenya was among the top 10 improvers.
Global trend towards regionalism

When conducting a survey on the tax/cash incentives that African countries avail to both local and foreign
investors, it is also important to understand this against the background of the political and economic trade
relations between African countries, as well as that between Africa and other regional trading blocks outside
of Africa.
In this context, an understanding of the various trade agreements that African countries have entered into and
the ability to traverse the unique complexities of each trade agreement, is necessary in order for business to
understand the level of access for their products into and within Africa. This, together with the extent of
costs associated to get such products to the markets that need them – is essential in any supply chain
operating within Africa.
A shift towards diversification

It is clear that many African countries specifically offer tax incentives to stimulate the manufacturing,
agricultural, and industrial base in their respective countries, with some more advanced economies also
offering incentives to localise financial services industries. A case in point is Kenya and Cameroon which
provides tax breaks for companies that list on its stock exchange. South Africa, Nigeria and Morocco are
notably the only countries in Africa that offer cash grants in addition to tax incentives, all of which require prior
approval by government.
We have noticed a recent trend in more African countries attempting to diversify their economies to shift
away from an over-reliance on extractive industries and to branch into mainstream industries such as
manufacturing and value-added services industries. African countries appear to be introducing new or revised
incentives, seemingly to compete more favourably for both local and foreign direct investment.
We are happy to answer any queries you may have, and look forward to building a lasting relationship with
you - giving your business the best possible advantage in an ever-increasing competitive environment.

Southern Africa
Green Point
stadium, Cape
Town
Angola
Tax incentive
Industrial Tax Code
PIL
PIL Tax Benefit regarding Micro, Small and Medium
Extraordinary tax
Tax incentives the Reinvestment of Businesses Law (MSMB)
benefits
Voluntary Reserves
• Foreign investments - Investments with a total Profits which were None

total amount equal or amount equal or higher taken to reserves and
higher than the amount in than the amount in reinvested, within the
Kwanzas corresponding Kwanzas corresponding to following three fiscal
to USD 1 Million; USD 50M may benefit from years, in new facilities
Minimum
extraordinary tax benefits. or equipment for
Investment • Domestic investments - manufacturing or
required total amount equal or Criteria:
administrative
higher than the amount • Create 500 or 200 jobs activities.
equivalent in Kwanzas for Angolan citizens, in
corresponding to USD Zone A or B,
0.5 Million. respectively.
100% tax reduction on To be negotiated with the Up to 50% of the A reduction of the standard
Industrial Tax, Real Estate relevant Authorities, and investment amount Industrial Tax rates may apply:
Transfer Tax ("Sisa") and expected to be more may be deducted to • Micro businesses – the
Tax on Invested Capital for beneficial than the standard the taxable income. Industrial Tax is replaced by
a period of 10 years (the PIL Tax Incentive. the payment of 2% over
percentage of reduction is gross sales, regardless of
based on a certain score the economic zone.
given to each investment
Maximum project depending on its • Small and medium
benefit compliance with the businesses – reduction of
available requirements set in the 50% for Zone A, 35% for
PIL. Zone B, 20% for Zone C and
10% for Zone D.
Exemption from Consumption
Tax over raw and subsidiary
materials
Exemption from Stamp Duty
applied to micro businesses.
Type of benefit Tax reduction Extraordinary Tax benefits Tax deduction Exemption and tax reduction
Training Benefit None
The incentive is available The incentive can only be The deduction is The reduction of Industrial Tax
for a period between 4 to claimed after approval of divided in the three is available for 5 years for Zone
Timeframe / 10 years and can only be the investment project. years following the A, 3 years for Zone B and 2
How to claim claimed after the approval conclusion of the years for Zone C and D.
of the investment project investment.

Angola (cont.)
Tax incentive
Industrial Tax
Code
PIL Tax Benefit Micro, Small and
PIL
Extraordinary tax regarding the Medium Businesses
Tax incentives
benefits Reinvestment of Law (MSMB)
Voluntary
Reserves
Criteria for the granting of tax benefits: The law is not entirely Taxpayers must Only Angolan entities
• Investment amount; clear whether the limits submit an that comply with the
• National jobs creation; related to the PIL application to the provisions of the MSMB
• Investment location; regarding the General Tax Law are eligible to be
• Angolan shareholders participation; percentage of Administration granted with these tax
• Domestic value-added; reduction and its before the end of incentives.
• Export-oriented production; duration period should February of the
• Agricultural, livestock, and agro- also be applicable to following year after
industries; the extraordinary tax the conclusion of Zone A: provinces of
• Investment location (Zone A or Zone B). benefits. the investment, Cabinda, Zaire, Uíge,
with supporting Bengo, Cuanza-Norte,
Zone A: documentation. Malanje, Cuando
Province of Luanda and the head Cubango, Cunene e
municipalities of the Provinces of Namibe;
Benguela, Huíla and the municipality of
Lobito.
Zone B: provinces of
Zone B: Cuanza-Sul, Huambo e
Provinces of Cabinda, Bié, Cunene, Bié;
Huambo, Cuango Cubango, Lunda-Norte,
Good to know Lunda-Sul, Moxico, Zaire, Bengo, Cuanza-
Zone C: provinces of
Norte, Cuanza-Sul, Malanje, Namibe and
Benguela, except the
Uíge and the other municipalities of the
cities of Lobito and
Provinces of Benguela and Huíla.
Benguela, and the
province of Huíla,
Entities registered in the Special
except the city of
Economic Zones may also benefit from
Lubango.
the following benefits:
• Exemption of customs duties on
exportation of goods produced in the Zone D: provinces of
SEZ; Luanda and cities of
• Exemption of customs duties on the Benguela, Lobito and
importation of goods incorporated in Lubango.
the production process for a period of
5 years;
• Exemption of customs duties on the
importation of machinery or other
equipment used in the offices for a
period of 10 years.

Botswana
Tax incentive
Manufacturing
International Financial Development approval
Development Approval Tax agreements
Services Centre (IFSC) order
Order
Minimum
Investment None
required
• A reduced corporate tax
rate of 15% applies to
approved activities.
• The Minister of Finance
• No withholding tax on may issue a
dividends, interest, development approval
• The Minister of Finance
royalties and order granting additional
and Development
management or relief to any project
planning can enter into
consultancy fees paid to which he considers
an agreement with any
a non-resident. would be beneficial to
A reduced corporate tax taxpayer.
Maximum the development of the
• Capital gains on rate of 15% and additional Botswana economy or • Once the agreement is
benefit
disposal of qualifying deductions as prescribed to the economic approved, a reduced tax
available
foreign shareholdings by the Minister. advancement of its rate, additional
are exempt. citizens. deductions and
• Dividends from exemptions prescribed
• Any order issued will
qualifying foreign by the Minister, would
specify the types and
participation are be available.
rates of additional tax
exempt. relief to be granted to
the project in question.
• Investors exempt from
capital gains tax on
divestment.
Tax reduction, Tax

Type of benefit Tax reduction, Tax Tax reduction, Tax deduction
deduction, Tax exemption
exemption
Training 200% tax deduction for approved citizen training, only to the extent to which such expenditure is not entitled to
Benefit reimbursement.
The Company has to

apply for and the The company has to apply
Minister has to issue for and the Minister has to The agreement has to be
How to claim / The Company has to
the Manufacturing issue the development approved by resolution of
Timeframe obtain certification first.
Development Order Order before the incentives the National Assembly.
before the incentives can be enjoyed.
can be enjoyed.
The economic
significance of the
project is a major
The economic significance of
determining factor in
the project is a major
the award of a
determining factor in the
Certification is dependent Manufacturing
award of a Development
on the level of Development Approval The agreement can only
Approval Order. In addition,
Good to know participation of citizens in Order. In addition, be amended or cancelled
consideration will be given to
management and training consideration will be by the National Assembly.
the plans or facilities in place
of citizen employees. given to the plans or
for the training of citizens
facilities in place for
and localisation plans of non-
the training of citizens
citizen held positions.
and localization plans
of non-citizen held
positions.

Malawi
Tax Allowances
Export Processing Zones
Claimed once-off Claimed Annually (EPZ)
Minimum
None.
Investment required
Initial allowances Annual allowances • Capital Equipment and raw
Annual allowances are available for materials are duty free.
Initial allowances are available on
capital expenditure during the year of qualifying assets on a declining • No excise tax is imposed on
acquisition at the following Rates: balance basis at the following purchase of raw materials
(i) Industrial buildings, Rates: and packaging materials
improvements, railway line 10% • Industrial buildings, farm made in Malawi.
(ii) Farm fencing 33.33% improvements & railway lines • No Value Added Tax, to
(iii) Machinery 20% 5% enjoy this you need to be
(iv) Automobiles forming part of a operating in the designated
commercial hire fleet 20%. • Farm fencing 10%
areas.
• Heavy machinery and
installations 15%
Investment allowances
• Light machinery 10%
Maximum benefit • There is also an additional of 15%
available allowance for investment in • Trucks and tractors 33.33%
designated areas of the country. • Light commercial vehicles
• Loss carry forward of up to six 25%
years. • Motor vehicles 20%
• Manufacturing companies may • Commercial Buildings costing
also deduct operating expenses more than K100 million 2.5%
incurred up to 25months prior to
Export allowance
the start of the operations.
A registered exporter, shall in
• There is also duty draw back when
every financial year during which
dealing in non-traditional exports
he exports products of Malawi, be
for all raw materials including
entitled to an income tax
packaging when registered with
allowance of 25 percent of his
Malawi Export Promotion Council.
taxable income derived from his
export sales.
Minimum
None.
Investment required
Transport allowance
An additional allowance may be
granted of 25 percent of the
international transport costs
incurred by a taxpayer for his
exports whether produced by
manufacturing in bond or
otherwise, but other than exports
of products specified in the
Maximum benefit Schedule to the Export Incentives
available (Exclusion) Order made under the
Export Incentives Act.
Mining allowance
A person carrying on mining
operations incurs mining
expenditure in any year of
assessment shall be entitled to an
allowance equal to 100 percent of
such expenditure in the first year
of assessment
Type of benefit Tax deduction
Training benefit None

Mozambique
Tax incentive
Foreign or Basic Infra- Manufacturing Agriculture Hotel and Large Special Industrial
National structure and Assembly and Fishing Tourism Dimension Economic Zones /
General Industry Projects Zones Freeports
Investment
MZN MZN Annual turnover MZN MZN MZN MZN MZN

2,500,000 2,500,000 over MZN 2,500,000 2,500,000 12,500,000 2,500,000 2,500,000
Minimum (1 USD = 3,000,000 and
Investment 68.0000 MZN) add value to the
required product of more
than 20%
• Accelerated • CIT Exemption of • CIT • Accelerated • Accelerated • CIT • CIT

depreciation reduction: customs duties reduction: depreciation depreciation reduction: reduction:
(more than 80% on the of material 80% until (more than (more 50%) exemption exemption
50%) for first five necessary for 31 50%) for for eligible on the first on the first
eligible years- 60% the production December eligible assets; five years- ten years-
assets; between or assembly, 2015- 50% assets; • Tax credit of reduction of reduction of
• Tax credit of sixth and including raw between • Tax credit of 5%-10% of 50% 50%
5%-10% tenth year- material. 2016 to 5%-10% of the between between
of the 25% 2025. the investment sixth and eleventh
investment; between • Exemption investment; done; tenth years- and
and eleventh to for customs • Exemption • Exemption reduction of fifteenth
fifteenth duties and 25% for the years-
Maximum • Exemption year. VAT on K
for customs for customs rest of the reduction of
benefit for customs duties and duties and project life. 25% for the
available duties and • Exemption class VAT on K VAT on all rest of the
VAT on K for customs equipment. class equipment • Exemption
duties and for customs project life.
class equipment necessary
equipment. VAT on K plus other for the duties and • Exemption
class equipment project. VAT on for customs
equipment. necessary equipment duties and
for the necessary VAT on
project for the equipment
project. necessary
for the
project
including
goods and
materials.
Type of
Tax deduction
benefit
Training None Training costs up to 5%-10% of the taxable None
costs up to profit.
Training 5%-10% of
Benefit the taxable
profit.

Mozambique (cont.)
Tax incentive
Foreign or Manufacturing
and Assembly Agriculture Large Special Industrial
National Basic Infra- Hotel and
Industry Dimension Economic Zones/
General structure and Fishing Tourism
Projects Zones Freeports
Investment
• Need to • Need to • Need to apply Need to Need to Need to • Need to apply for pre-
apply for apply for pre- for pre- apply for apply for pre- apply for pre- approval before company
pre- approval approval pre- approval approval can claim. The process
approval before before approval before before takes around 6 months.
before company can company can before company can company can
company claim. The claim. The company claim. The claim. The
can claim. process process takes can claim. process process
Good to The takes around around 9 The takes around takes around
know process 3 months. months. process 9 months. 12 months.
takes • The benefit • Benefit is takes
around 3 is available available for around 6
months. for 5 years the project months.
• Benefits for the period.
valid for 5 customs
years. duties and 15
year for CIT.

Namibia
Tax incentive
Export Processing Zone (EPZ) Tax Registered Manufacturers Tax Exporters of manufactured goods
Incentives Incentives Tax Incentives
Minimum
Investment None
required
• Exemption from: VAT, CIT, Stamp • An additional 25% deduction on A deduction of 80% of taxable
and Transfer duty, Customs and any expenditure incurred directly income (excluding the exporting of
Excise duty, No duty or tax on any in the manufacturing process; fish and meat products).
goods exported from Namibia;
and • An additional 25% deduction of
transportation cost incurred by
• Exemption from import VAT road or by rail;
Maximum
charged on the import of raw
benefit • Building allowance of 20% in the
materials and machinery used in
the manufacturing process. first year and the balance at 8%
available
per year over the ensuing 10
years; and
• An additional 25% deduction of
expenditure incurred as a result of
marketing for exportation
purposes.
Type of benefit Tax exemption Tax deduction
75% refund of expenditure incurred An additional deduction of 25%

Training from income will be allowed on None
in training Namibian citizens.
Benefit approved technical training
expenses.
• Tax incentives are of unlimited • Tax incentives are limited to the Registration with authorities is
duration. period the enterprise retains its required.
manufacturing status.
• No strikes or lock-outs are
allowed in an EPZ thus the • A physical inspection of the
Good to know enterprises should enjoy industrial premises is required before
calm. EPZ enterprises are allowed manufacturing status can be
to hold foreign currency accounts granted.
in local banks and they are free to
locate their operations anywhere
in Namibia.

South Africa
Tax Incentives (Table 1)
Research and
Greenfield and
Development Energy Efficiency
Brownfield Special Economic Employment Tax
(“R&D”) Tax Tax Deduction
Expansion projects Zones Incentive
Incentive (Section 12L)
(Section 12I)
(Section 11D)
None, but need to be

Greenfield projects: an employer duly
None, however registered for Pay As
Minimum • R50 million. project needs to be You Earn (“PAYE”)
Investment None None
Brownfields: located in a and must employ
required
designated SEZ. employees earning
• R30 million. between R2 000 to
R6 000 per month.
• Reduction in 50%
of PAYE during
Unlimited benefit. each month of the
150% tax deduction 15% corporate tax first 12 months in
on qualifying rate, accelerated 10 respect of which an
expenditure at a year allowance on The deduction is employer employs
corporate tax rate of buildings, VAT and calculated at 95 cents a qualifying
Maximum 28%. This is R98 million to Customs relief and per kilowatt hour of employee; and
benefit effectively an R252 million net tax the Section 12I tax energy efficiency • Reduction in 25%
available additional 14% tax benefit. incentive is available savings or energy of PAYE during
saving on qualifying as well as an efficiency savings each of the 12
expenditure with no employment tax equivalent. months after the
upper cap or limit on incentive to hire first 12 months that
the allowed more people. the same employer
expenditure. employs the
qualifying
employee.
Type of benefit Tax deduction
R36 000 per
employee up to a
Training Benefit Not applicable. None
maximum of
R30 million.
From 1 October 2012, The incentive is

the effective 14% tax A Company needs to The energy efficiency available from 1
saving can only be submit an application, The SEZ Act was savings have to be January 2014 to 28
How to claim / claimed from the date which must be promulgated on 9 measured and February 2019.
Timeframe a pre – approval approved before February 2016, and is confirmed by a
application form has contracting for or currently effective. certified and
been lodged with the acquiring any assets. accredited body.
DST.

South Africa (cont.)
Tax Incentives (Table 1 – continued)
Research and
Greenfield and
Development Energy Efficiency
Brownfield Special Economic Employment Tax
(“R&D”) Tax Tax Deduction
Expansion projects Zones Incentive
Incentive (Section 12L)
(Section 12I)
(Section 11D)
Various zones have • No deduction is
been identified allowed if the
across South Africa: taxpayer receives a • Eligible employers
• Dube Trade Port; concurrent must employ
government benefit qualifying
• Richards Bay; in respect of employees who are
The time frame for energy efficiency between 18 to 29
• Saldanha Bay; savings; and years old at the end
pre – approval from
date of lodgement is • Atlantis; of the month the
• A deduction for incentive is
generally about 9 The time frame for captive renewable
• Upington; claimed, and who
months, with approval from date of energy is only
Good to know expenditure lodgement is have South African
• Harrismith; allowed under
qualifying from the generally at least 2 -3 Identity documents
section 12L if the or asylum seeker
date of lodgement of months. • Johannesburg (x2);
kilowatt hours of permits; and
the pre – approval energy output of
• Rustenburg;
application to the the respective • Age limit is not
DST. • Tubatse; captive power plant applicable if the
• Port Elizabeth; is more than 35% employee renders
of the kilowatt their services to an
• East London; and hours of energy employer who
input in respect of operates in a SEZ.
• Messina. that year of
assessment.

South Africa (cont.)
Government Grants (Table 2)
Aquaculture Business Process
Development and Critical Infrastructure Services (BPS)
Film Incentive
Enhancement Program (CIP) (e.g. call centre / shared
Programme (“ADEP”) services)
None, but need to
conduct activities that fall
under the Standard
Create at least 50 new • R 12 Million for foreign
Industry classifying code
Minimum jobs in South Africa over a Films.
(SIC) 132 (fish hatcheries
Investment None three year period and
and fish farms) and SIC • R 2.5 Million for South
required maintain the jobs for a
301 and 3012 (production, African Films.
period of five years.
processing and
preserving of aquaculture
fish).
• Average cash incentive
of R22 000 to R34 000
per job retained (2014
The grant ranges to 2023).
between 25% and 45% 20% - 50% of production
Cash grant of between
Maximum of the cost for a new, • 20% bonus if more than expenditure and up to
10% to 30% of
benefit upgrade or expansion greater than 400 but 5%- 25% of Post
investment, Capped at
available project (based on a point less than 800 jobs production Expenditure.
R30 million.
scoring system), capped created. Capped at R50 million.
at R40 million.
• 30% bonus if more than
greater than 800 jobs
created.
Type of benefit Cash grant
Training
None
Benefit
• Claim application must
be submitted to the DTI
at least 2 months • The incentive consists
before commencement of three categories:
of operations, for grant – Foreign Film and
to be disbursed. Television Production
• Applications must be and Post-Production
• Projects will be granted submitted 3 months incentive;
an incentive payment before start of • Must commence
and disbursement construction of commercial BPS – South African Film
period based on their infrastructures; and operations no later than and Television
investment spread as: six months from the Production and Co-
(i) Projects with a • Incentive applies to Production incentive;
Good to Know approval date.
proposed one year both mining and and
investment are granted manufacturing • The 50 new jobs
an incentive, and industries. created must be – South African
disbursement over two retained. Emerging Black
• Applicants claim is Filmmakers incentive.
six monthly periods
linked to a scorecard,
(ii) Projects with a Applications must be
measuring level of •
proposed two year submitted before
investment and
investment are granted commencement of
percentage of black
an incentive payment principal photography
ownership.
and disbursement over or post production.
four six monthly
periods.

Swaziland
Swaziland does not offer cash grants to companies. There is no capital gains tax in Swaziland.
Tax Incentives
Special Economic
Development Duty free access for
Rebates for raw Zones
Approval Order capital goods and Building Initial Allowance
material (Industrial
(DAO) machinery
Zones/Freeports)
Minimum
Investment None
required
10% maximum Exemption of Exemption from Industrial Building Allowance.
CIT payable for equipment and import duty on Initial allowance of 50% of
10 years. No machinery from raw material the actual cost of a building,
withholding tax duties only those used to for the first year and 4% Government has
Maximum on dividends imported for manufacture thereafter.
benefit identified two
paid. purposes of goods to be areas (Royal
available manufacturing or exported outside
Reduced CIT rate Science and
direct operations. the Southern Technology Park
by 17.5% African Customs
(normal rate is and the King
Union (SACU). Mswati III
27.5%).
Type of International
Tax Reduction Tax exemption Upfront reduction in tax. Airport) that have
benefit
Yes (Available for been earmarked
Training as Special
Research and None
Benefit Economic Zones.
Development)
On importation Written application to

Timeframe/ Swaziland Revenue Authority
10 years Completion of documents at border.
How to (SRA) on commencement of
(Renewable) Private clearing agents available to assist
Claim project and inspection of
taxpayers completed project by SRA.
Also includes Administered under N/A In respect of buildings other
relief from the SACU Common than hotels and
dividend External Tariff (CET) improvements if such
Government is
withholding tax Framework. building is wholly/mainly
currently working
for the same 10 used for the purpose of
on the legislation
year period. The housing machinery or plant
to ratify these
Good to normal rate is for the year of assessment
areas and the
Know 15% but this can during which the building is
additional
be reduced first used. Similar allowances
benefits to be
through the are available for hotel
made available.
application of buildings and plant and
various Double machinery used in a
Tax Agreements. manufacturing process

Zambia
Tax incentive
Special Economic Zones

ZDA investment incentives Industry Specific Incentives
(Industrial Zones/Freeport's)
Currently $500k, (please note that Multi-facility economic zones or None
Minimum this may be been increased to industrial parks are located both in
Investment $2.5m per latest proposed Lusaka and the Copper belt.
required amendment of ZDA bill). Investment in rural areas also
qualifies for incentives.
• 0% corporate income tax for 5 ZDA incentives as described across • 10% corporate income tax rate
years; are only available in the approved (35% standard rate) and
multi-facility economic zones, increased capital allowances;
• Dividend withholding tax at 0% industrial parks or rural areas.
for 5 years; • The export of non-traditional
goods benefits from a 15%
• Improvement allowances of corporate income tax rate;
Maximum
100% on certain capital
benefit
expenditure; and • The manufacture of certain
available
fertilizers benefits from a 15%
• The suspension/deferment of corporate income tax rate; and
import duties and import VAT on
plant and machinery for 5 years. • Rural enterprises benefit from a
30% corporate income tax rate
for the first 5 years.
Type of benefit Tax reduction

Training
None
Benefit
In order to claim these, the investment must initially be approved by the Zambia Development Agency, and then
confirmed by the Zambia Revenue Authority. The incentives are available for 5 years from the commencement of
Good to Know the business.
Please also note that companies listed on the Lusaka Stock Exchange can benefit from slightly reduced corporate
income tax rates in the year after listing, provided that certain conditions are met.

Zimbabwe
Tax Incentives
Build, own, operate and
Industrial Park Developer Manufacturing exporter
transfer (BOOT or BOT)
None, but needs to conduct

None, but usually
manufacturing operations in
encompasses large scale
Minimum Investment None, but needs to operate Zimbabwe and, in any year of
construction projects such as
required in an approved industrial park. assessment, 30% or more of its
construction of roads,
total manufacturing output is
infrastructure, etc.
exported from Zimbabwe.
Company which exports

between 30% to 41% of its
The rate of tax for BOOT or output will be taxed at the
BOT operations is 0% in the preferential rate of 20%. If the
Maximum Benefit first five years, 15% in Taxed at 0% in first five years Company exports more than
available respect of the second five and 25% thereafter. 41% but less than 51% , the
years and then 25% CIT rate drops to 17.5%; If the
thereafter. company exports more than
51%, then the CIT rate comes
down to 15%.
Type of benefit Tax exemptions, Tax

Tax reduction Tax reduction
reduction

“Industrial park” means any
An approved BOOT or BOT
premises or area which is
arrangement is a contract /
approved by the Minister by
arrangement approved by the
statutory instrument and in
Commissioner-General, to
which two or more persons,
construct an item of
independently of the Percentages of a company’s
infrastructure for the state or
industrial park developer, manufacturing output are
Good to know a statutory corporation, and
carry on the business of: calculated by quantity or volume
the right to operate or control
manufacturing or processing rather than according to value.
it for a specified period, (after
goods for export from
which period the ownership
Zimbabwe; or manufacturing
or control is transferred or
or processing components of
restored to the state or the
goods which are intended for
statutory corporation).
export from Zimbabwe.

Eastern
Africa
Mount
Kilimanjaro
Tanzania
Burundi
Tax incentive
Profit Tax discount of 2% Profit Tax discount of 5%
(Industrial Zones/ Free ports)
Minimum • Registered and employing
• Registered and employing
Investment between 50 to 200 None
more than 200 Burundians.
required Burundians.
Maximum Benefit • Profit Tax discount of 2%. • Profit Tax discount of 5%. • 0% Corporate Income Tax
available (CIT)
• Reduced Corporate Income

Type of benefit Tax exemption
Tax (CIT).
• Losses are carried forward for

Good to know
5 years.

Ethiopia
Industries applicable for incentives include, but are not limited to, Manufacturing, Agro-industries, ICT,
Textiles, Timber, Chemical and Pharmaceutical, Food and Minerals. Non- fiscal incentives are given to all
investors who produce export products.
Tax incentive
Regional Income Tax Non Fiscal (Export) Customs Duty
Income Tax Holidays
deductions Incentives Exemptions
None, but an investor must
establish a new enterprise • None, but all foreign
in one of the following investors in Ethiopia are
regions: required to invest at least
Gambella; Benshangul/ US$ 200,000 (or an
None, but an investor Gumuz; Afar; Somali; Guji equivalent amount in
must be engaged in and Borena Zones (in None, but must be Ethiopian birr at the
manufacturing, Oromia); or designated as either a prevailing exchange rate)
Minimum in a single investment
agribusiness; South Omo Zone, Segen ‘producer exporter’,
Investment project; and
generation, (Derashe, Amaro, Konso ‘indirect producer
required
transmission and and Burji) Area Peoples exporter’, ‘raw material • Investor must be
supply of electrical Zone, Bench-Maji Zone, supplier’ and ‘exporter’. engaged in
energy; and ICT. Sheka Zone, Dawro Zone, manufacturing,
Keffa Zone, Konta and agribusiness, generation,
Basketo Special Woredas transmission and supply
(in Southern Nations, of electrical energy; and
Nationalities and Peoples ICT.
Region).
100% exemption from
Income tax customs duties and other
30% income tax deduction • Qualifying investors are taxes levied on:
exemptions for a
for three consecutive years allowed to import
Maximum period ranging • importation of capital
after the expiry of the tax machinery and
benefit between 1 and 9 goods and construction
holiday period, as shown equipment necessary
years, depending on material; and
available on the left hand column, for their investment
the specific activity • imports on spare parts
under “Income Tax projects through a
and the location of the (the value of which is not
Holidays”. suppliers’ credit.
investor. greater than 15% of the
total value capital goods).
Suppliers Credit, Tax
Type of benefit Tax exemption Tax deduction Customs Duty Exemption
exemption
• Companies that
incur losses during
the income tax
holiday period are
allowed to carry An investor who expands
forward such losses or upgrades his existing
enterprise and increases its Business enterprises that • Although no particular
for half of the
production or service suffer losses during the time frames are given for
income tax holiday
capacity by at least 50%, income tax exemption approval, approvals must
period after the
or introduces a new period can carry forward be obtained in advance
expiry of the holiday
production or service line such losses, following the before such importation
Good to Know period, however the
at least by 100% percent expiration of the income of duty free goods.
period may not
exceed a 5-year of an existing enterprise, tax exemption period, for • The incentive is available
income tax period. may be entitled to the half of the tax exemption for the importation of
income tax exemption on period but up to a spare parts is limited to a
• The tax holidays the left hand column, maximum of 5 years. period of 5 years.
may be extended under “Income Tax
for an additional Holidays”.
period of 2 years
subject to meeting
certain export
requirements.

Kenya
Kenya provides a number of incentives, especially for investors in the manufacturing sector. However, the
recently enacted Special Economic Zone Act extends incentives to other sectors including services which are
established in designated zones.
Tax Incentive
Nairobi Stock
Export Processing Special Economic Investment Employment Tax
Exchange (NSE)
Zones (EPZ) Zones (SEZ) Deduction (ID) Incentives
Listing Incentive
100% ID no
minimum
investment is
required.
Minimum None, but need to None, but need to
Investment be located in a be located in a 20% issued shares. 150% ID in an area None
required designated EPZ. designated SEZ. outside major cities
and a minimum
investment of KES
200 million is
required.
10 year corporate tax

holiday and 25% tax
rate for next 10
years.
Withholding tax
holiday on dividends
and other
remittances to non-
residents.
Tax exemption on
Exemption from VAT 150% Deduction on overtime, bonuses
Reduced corporate
and customs import Corporate tax rate at qualifying cost of and retirement
Maximum tax rate at 10% for
duty on inputs and 20% for first 5 years investment for benefits for
benefit the first 10 years and
stamp duty. after listing 40% or investments outside employees earning
available 15% for the next ten
more issued shares. the three major and income of less
Exemption from VAT years.
cities. than KES 11,180 per
registration. month.
Exemption from
payment of excise
duty.
100% investment
deduction on new
buildings and
machinery within the
EPZ.
Type of Tax exemption and
Tax exemption Tax reduction Tax deduction Tax exemption
benefit tax reduction
Training Taxpayers registered with the National Industrial Training Authority (NITA) contribute monthly Industrial Training Levy
Benefit and are entitled to a reimbursement of training costs so long as the training is carried out by NITA Certified Trainers.

Kenya (cont.)
Tax Incentive
Export Processing Nairobi Stock
Zones (EPZ) Special Economic Investment Employment Tax
Exchange (NSE)
Zones (SEZ) Deduction (ID) Incentive
listing incentive
3 – 5 years
Timeframe 10-20 years 10-20 years depending on %age None None
of listed shares.
Manufacturing, SEZs may include Company that lists Available to This is effective from
commercial or free trade zones, 20% issued shares qualifying 1 January 2017.
service activities industrial parks, free enjoy 27% corporate investments
may be undertaken ports, ICT parks, tax for the first three (infrastructure or
in an EPZ. science and years. development).
technology parks,
May be 100% agricultural zones, Company that lists Investments located
foreign owned. tourist and 30% issued shares within Nairobi,
Good to recreational zones, enjoy 25% corporate Mombasa, Kisumu
Licensing of EPZ tax for first five qualify for 100%
Know done by EPZ business service
parks and livestock years. deduction.
Authority of Kenya.
zones. Company that list
40% issued shares
Licensing of SEZs enjoy 20% corporate
done by Special tax for first five
Economic Zones years.
Authority.

Mauritius
Some of the government incentives include a single corporate income tax rate (“CIT”) of 15 percent;
exemption from customs and excise duties on import of equipment and raw materials; exemption from tax
on payment of dividends, no capital gains tax; a low 5% registration duty on registration of notarial deeds;
free repatriation of profits, dividends, and capital; and reduced tariffs for electricity and water for vulnerable
people.
Tax incentive(Table 1)
Global Headquarters Global Treasury Global Legal Advisory
Non Citizen individuals
Administration Activities Services
No minimum threshold of No minimum threshold of No minimum threshold of • Minimum investment
investment required. investment required. investment required. required is USD 25
However, the applicant However, the applicant However, the applicant million in Mauritius; or
must provide at least 3 of must provide at least 3 of should be an entity which • A company wholly
the following services to the following services to is licensed or registered owned by a non-
at least 3 related at least 3 related as a law firm in a foreign citizen investing not
corporations to benefit corporations to benefit country and should less than USD25
from this licence: from this licence: ensure the following: million in the company
• It must also employ • Arrangement for • The applicant should
10 professionals with credit facilities, appoint at least five
at least two at including credit lawyers
managerial positions facilities with funds • The parent law firm is
and incur annual obtained from qualified, licensed or
expenditure of MUR 5 financial institutions in regulated as a firm
million (approx. USD Mauritius or from entitled to practice
Minimum law in its home
Investment 143k) surpluses of network
companies jurisdiction;
required • 2 foreign lawyers
• Arrangement for qualified in the foreign
derivatives Corporate jurisdiction in which
finance advisory the applicant is
• Credit administration registered in should
and control practice the law of
that jurisdiction and
• It must employ four
are employed by or
professionals with at
are part of the entity;
least one at
and
managerial position
• The applicant has a
and incur annual
physical
expenditure of MUR 2
establishment in
million (approx. USD
Mauritius.
58k)
Maximum 8-year tax holiday 5-year tax holiday 5-year tax holiday 5-year tax holiday
Benefit
available

Rwanda
The 2015 Investment promotion law came with new incentives that are critical towards driving the growth
of key priority sectors: exports, energy, ICT, transport and logistics, health, manufacturing, financial services,
tourism and affordable housing.

Preferential Preferential corporate income tax Corporate Corporate income tax
corporate income rate of fifteen percent (15%) income tax holiday of up to five (5)
tax rate of zero per holiday of up years
cent (0%) to seven (7)
years
An international • An investor exporting at least 50% An investor Microfinance institutions
Company with of its turnover or investing in one investing at approved by National
headquarters or of the Economic priority sector, least 50,000 Bank of Rwanda (BNR)
regional office in such as Information USD and are entitled to a tax
Rwanda, fulfilling Communication Technology (ICT), contributing at holiday of five years (5
investment Transport, Energy, least thirty years) from the time of
requirements such as • A registered investor, exporting at percent (30%) their approval, which may
invest at least: least 50% of turnover of goods of this be renewed.
• USD 10,000,000, in and services produced in Rwanda, investment in
both tangible or including business processing form of equity
intangible assets, in outsourcing. in the
Rwanda. Economic
• A registered investor undertaking Priority Sectors,
• Provide employment
and training to
one of the following operations: such as
Minimum energy generation, transmission Energy,
Rwandans
Investment required and distribution from peat, solar, Tourism,
• Conduct international
geothermal, hydro, biomass, Health,
financial transactions
of at least 5,000,000 methane and wind. This incentive Manufacturing,
USD a year. excludes an investor having an ICT and Export
engineering procurement contract related
• Use equivalent of at
least 2,000,000 USD in executed on behalf of the investment
Rwanda as well as Government of Rwanda. projects.
others requirements. • A registered investor in the sector
• Set up actual and of transport of goods and related
effective activities whose business is
administration and operating a fleet of at least five (5)
coordination of
trucks registered in the investor’s
operations in Rwanda
name, each with a capacity of at
least twenty (20) tons.

Rwanda (cont.)
Tax Incentives (Table 1 - cont.)
Preferential Preferential
Corporate income tax Corporate income tax
corporate income corporate income tax
holiday of up to seven holiday of up to five (5)
tax rate of zero per rate of fifteen
(7) years years
cent (0%) percent (15%)
• Preferential • Preferential corporate • Corporate income tax • Corporate income tax
corporate income income tax rate of holiday of up to seven (7) holiday of up to five (5)
tax rate of zero per fifteen percent (15%) years years
cent (0%) • The investor is • The investor is • The investor is
• The investor is exempted from exempted from capital exempted from capital
exempted from capital gain tax gain tax gain tax
capital gain tax • The refund of VAT • The refund of VAT paid • The refund of VAT paid
• The refund of VAT paid by investors is by investors is done by investors is done
paid by investors is done within 15 days within 15 days upon within 15 days upon
done within 15 upon receipt of the receipt of the request receipt of the request
days upon receipt request
• An investor and his/her • An investor and his/her
of the request
Maximum Benefit • An investor and dependents are issued dependents are issued
available • An investor and his/her dependents with a residence permit, with a residence permit,
his/her are issued with a when he/she invests at when he/she invests at
dependents are residence permit, least 250,000 USD may least 250,000 USD may
issued with a when he/she invests recruit three foreign recruit three foreign
residence permit, at least 250,000 USD employees without employees without
when he/she may recruit three further formalities. further formalities.
invests at least foreign employees
250,000 USD may without further
recruit three formalities.
foreign employees
without further
formalities.
Type of benefit Tax Deduction Tax Holiday
Training Benefit Not applicable

• It has to be an • Application of the • Applications must be • Application must be
international incentives is applied submitted 60 days approved by the
company which during the before start of National Bank of
has its registration Process. production. Rwanda (BNR).
headquarters or • The Ministerial Order • The Ministerial Order will • This period may be
regional office in will come to list all come to list all Specific renewed upon fulfilling
Rwanda. Specific sectors sectors which will be conditions prescribed in
• All registered which will be subjected to this the Order of the
Good to know investors shall not subjected to this Incentive. Minister in charge of
pay capital gains Incentive. finance.
tax, and all foreign
investors are
entitled to
immigration
assistance.

Rwanda (cont.)

Accelerated Depreciation
(Industrial Zones/ Free ports)
• Invest in Business Assets worth at least USD 50,000 in sectors such as
Exports, manufacturing, telecommunications, agro-processing, education,
health, tourism, construction etc. And keep the asset at least for 3 years
• Transport excluding passenger vehicles with less than nine (9) people
seating capacity;
• Tourism investments worth at least one million eight hundred thousand
United States Dollars (USD 1, 800, 000);
• Construction projects worth at least one million eight hundred thousand
United States dollars (USD 1,800,000);
Minimum • Any other sectors provided the investment is worth at least one hundred
Investment None thousand United States dollars (USD 100,000);
required • The investor is required; to keep the assets for at least three years after
benefiting from the accelerated depreciation; to inform the Commissioner
General of the Rwanda revenue authority of the disposal of the business
assets in case such disposal is made before three years.
• Where an investor makes the disposal of such assets before the
expiration of three years, he/she has pay the difference from the
reduction of corporate income tax caused by the accelerated depreciation
as well as any applicable penalties and interests. However, the investor
will not be liable to pay any amount where it is determined that such
disposal was the effect of natural calamities, hazards or any other
involuntary reason.
• The investor is exempted from • Accelerated Depreciation rate of 50% for the first year for new or used
customs taxes and duties for assets.
products used in Export • The investor is exempted from capital gain tax
processing zone, Pay corporate
Income at a rate of 0%, • The refund of VAT paid by investors is done within 15 days upon receipt
exemption from withholding tax, of the request
tax free repatriation of profit. • An investor and his/her dependents are issued with a residence permit,
• The investor is exempted from when he/she invests at least 250,000 USD may recruit three foreign
capital gain tax employees without further formalities.
Maximum Benefit
available • The refund of VAT paid by
investors is done within 15 days
upon receipt of the request
• An investor and his/her
dependents are issued with a
residence permit, when he/she
invests at least 250,000 USD may
recruit three foreign employees
without further formalities.
Reduced Corporate Income Tax

(CIT), VAT refunded within 15 days
Type of benefit and benefits of duty free or free Tax deduction
trade zones.

• The investor need to be located
in a designated SEZ (located in
Kigali) investing in products for
When the assets is disposed before the expiration of 3 years, the investor
Export purposes.
Good to know need to inform the commissioner General of the tax administration.
• A special Economic Zone was
prepared in Kigali, the
Government calls upon investors
to establish their industries.

Somaliland
The Somaliland Government operates a tax incentive scheme in respect of foreign investments in 11 key
sectors. These incentives are based on Somaliland Companies Law and laws pertinent to the Promotion,
Protection and Guarantees of Foreign Investments in that jurisdiction.
– Investment that puts productive use country’s human and natural resources;
– Investment that introduces innovative technology;
– Investments that generate foreign exchange or substitute imports;
– Agriculture;
– Livestock;
– Fishing;
– Minerals;
– Oil & gas;
– Industries that use local inputs (machinery, equipment and material);
– Utilities (water and energy);
– Tourism.
Tax incentives can include a three year tax holiday extendable on agreement and a subsequent 50%
reduction in taxes payable for a further period of the same duration. More detailed guidance and advise on tax
and foreign investments and legal matters in Somalia are available from Africa Legal Risk Control Ltd.

South Sudan
Tax incentive
Agriculture and agribusiness Quarrying and mining Priority areas

Minimum
Investment None
required
100% allowance on scientific research, repairs and minor capital equipment, 75% for plant and machinery set up in
Maximum
least developed areas, 25% for start up costs incurred in setting up equipment, 40% for start up costs incurred in
benefit
setting up equipment in least developed areas, 20% for the first year in which the industrial buildings (commercial
available
buildings excluded), 30% farmworks deduction, special wear and tear allowances ranging from 10% to 40%*
Capital allowances, deductions in

respect of training, scientific research,
Type of benefit industrial building deductions, Capital allowances, deductions in respect of training, scientific research*
exemption from duty on importation of
agricultural material*
Capital allowances time frame Lifespan of the quarry/mine ,capital Capital allowances time frame
dependent on allowance granted for allowances time frame dependent on dependent on allowance granted for
Timeframe each type of asset, six years for allowance granted for each type of each type of asset, six years for
training, three years for scientific asset, six years for training, three training, three years for scientific
research* years for scientific research* research*
Training
100% cost on training allowance granted on training a South Sudan citizen. This incentive will not go beyond six
Benefit
years*
available
General investment in agriculture shall
not exceed 30 years. Renewal will be None
subject to agreement between the
government and the investor.*
Other practical
comments – All investments are subject to the investor obtaining the investment certificate from the South Sudan Investment
where Authority*
applicable
Investments with quicker returns have a shorter period of enjoying concession periods*
No cash grants provided by the Government of South Sudan*
*The Taxation Amendment Act 2016 which was to take effect from 20 December 2016 repealed all the above tax
incentives. The repeal is attributable to dwindling cash reserves as a result of declining petroleum revenues and civil
Note
unrest. However, there is no communication on the implementation date for the repeal.

Tanzania
The incentives are structured according to the lead and priority sectors including; Agriculture & Livestock,
Tourism, Manufacturing, Commercial Building, Transportation, Broadcasting and Telecommunication, Natural
Resources, Financial Institutions, Energy, Human Resources Development, Economic/ Infrastructure.
Tax incentive
Export processing zones (EPZs) Special Economic Zones (SEZ) Other incentives
• Qualifying investments are
investments made in the priority
sectors with an investment
capital amount of above US$
For EPZ User Licence, the 100,000 in the case of local
minimum capital is US$ 500,000 for For SEZ User Licence, the investors and above US$ 500,000
Minimum
foreign investors and US$ 100,000 minimum capital is US$ 500,000 for in the case of foreign investors.
Investment
for local investors. The investment foreign investors and US$ 100,000
required • Special strategic investment
must be new and the project needs for local investors.
to be located in a designated EPZ. status may be granted to project,
which meet among other criteria
of which, a minimum investment
capital of not less than US$
300,000,000 is required.
• Exemption from payment of corporate tax for 10 years; A certificate of incentives
• Exemption from payment of withholding tax on rent, dividends and guarantees:
interest for 10 years; • fiscal stability for a 5-year period,
i.e. protection against adverse
Maximum • Reduction of customs duty, VAT and any other tax payable on raw changes in taxation legislation;
benefit materials and goods of a capital nature; and
available • Exemption from payment of all local taxes and levies imposed on goods • the right to transfer outside the
and services produced or purchased in the EPZ for a period of 10 years; country 100% of profits (including
• Exemption from VAT on utility and wharfage charges; and foreign exchange earned) and
• No stamp duty. capital.
Type of benefit Tax exemptions Tax reduction Tax reduction

Training
None
Benefit
For certain type of taxes, you will need to show the certificate of incentives
Timeframe / issued by the EPZ or SEZ and an application letter in order to claim An application must be submitted
How to claim exemption. However, for certain tax exemption, there is no pre-approval to the TIC.
requirements.
Only holders of licences granted by

the EPZA may:
• Conduct a business or undertake
a retail trade in an EPZ in respect
of any goods manufactured in, or
imported into, such EPZ; The Investment Act (“IA”) provides
• Remove goods manufactured in The investment must be new and for issuance of “certificates of
Good to know an EPZ for any purpose other the project needs to be located in a incentives” to qualifying investors
than conveyance to another EPZ designated SEZ. who have made applications for
or export into a foreign market, or such certificates to the TIC.
for purposes of processing such
goods only; or
• Use goods manufactured in an
EPZ for consumption in such EPZ
or in any other EPZ.

Uganda
Tax Incentives Table 1
Collective Investment
Agro-processors Exporters of finished goods
Scheme
Minimum
Exports greater than 80% of
Investment None
the total production.
required
Income of the collective Income of a person for a year of A person who derives income
investment scheme to the income that is derived from agro- from exportation of finished
Maximum extent that it is distributed to processing is exempted from consumer or capital good is
benefit the participants in the income tax exempted from income tax
available scheme is exempted from for a period of 10 years.
income tax
Type of
Tax exemption Tax holiday
benefit
Training
N/A
Benefit
In order to qualify, the • A person shall not qualify for this To qualify, a person should
participants create an exemption if they or their apply and be issued with a
arrangement in which they associate has carried on agro- certificate of exemption
pool property (including processing of a similar or related issued by the Commissioner
money). They then become agricultural product in Uganda. for both new and existing
owners of the property in • To qualify, a person should apply investments in accordance
order to receive income and be issued with a certificate of with the regulations.
from such an arrangement. exemption issued by the
The participants do not have Commissioner. This certificate will
day to day control over the The certificate is valid for ten
be issued if the person is years.
Good to management of the property compliant and is valid for one year
know but may be consulted and may be renewed annually.
• The person should as well invest
in plant and machinery that has
not been previously used in
Uganda by any person in agro-
processing to process agricultural
products for final consumption.
• The person processes agricultural
products grown or produced in
Uganda.

Uganda (cont.) Tax Incentives Table 2
Withholding VAT (zero rated
Capital Allowances Foreign Tax Credits VAT (exempt supplies)
Tax supplies)
• Start up cost spread Exemption A resident taxpayer is VAT is exempted from the supply of; The following
equally over 4 years from 6% entitled to a foreign • social welfare services; supplies are zero
(25% of the cost per withholding tax credit for any rated;
annum). tax on goods foreign income tax • financial services • Export of goods or
• Scientific research and services paid by the taxpayer in • education services services from
expenditure is an respect of foreign- Uganda as part of
allowable tax expense source income which • burial and cremation services; the supply;
(100% of the cost) is included in the • betting, lotteries and games of • international
• Training expenditure is gross income of the chance transport of goods
an allowable taxpayer. or passengers and
• passenger transportation services
expenditure. (100% of tickets for their
(other than Tour and Travel
the cost) transport
operators)
• Industrial building • drugs and
deduction for a • dental ,medical and veterinary medicines
qualifying building that goods • seeds, fertilizers,
is put to use in a year • photosensitive semiconductor pesticides, and
of income is an devices, including photo-voltaic hoes;
allowable for tax devices, whether or not assembled • sanitary towels and
purposes. (5% of the in modules or made into panels; tampons and inputs
cost per annum on a light emitting diodes; solar water for their
straight line basis) heaters, solar refrigerators and manufacture.
• Depreciable assets are solar cookers • educational
classified as specified materials
in the law and enjoy • life jackets, lifesaving gear, head • leased aircraft,
wear and tear between gear and speed governors aircraft engines,
20% - 40% of the cost • machinery, tools and implements spare engines,
on a reducing balance suitable for use only in agriculture spare parts for
basis. • aircraft and aircraft
• postage stamps
• Losses on disposal of maintenance
property, plant and • unimproved land Equipment.
Maximum equipment is an • life, health, micro and re-insurance • Cereals grown and
benefit allowable expense for insurance services; milled in Uganda.
available tax purposes.
• unprocessed foodstuffs,
unprocessed agricultural products
• veterinary, medical, dental and
nursing services
• precious metals and other
valuables to the Bank of Uganda
for the State Treasury
• by way of sale, leasing or letting of
immovable property, other than;
(i) a sale, lease or letting of
commercial premises
(ii) a sale, lease or letting for
parking or storing cars or other
vehicles;
(iii) a sale, lease or letting of hotel
or holiday accommodation;
(iv) a sale, lease or letting for
periods not exceeding three
months; or
(v) a sale, lease or letting of
service apartments
• petroleum fuels subject to excise
duty,(motor spirit, kerosene and
gas oil), spirit type jet fuel,
kerosene type jet fuel and residual
oils for use in thermal generation
to the national grid.
Uganda (cont.)
Tax Incentives Table 2 (cont.)
Withholding VAT (zero rated
Capital Allowances Foreign Tax Credits VAT (exempt supplies)
Tax supplies)
Minimum
Investment None
required
Type of
Tax deduction Tax exemption Tax deduction Tax exemption Tax exemption
benefit
Only training expenses
Training relevant to an
N/A
Benefit employee’s line of work
is allowable.
• The Income Tax Act This • The amount of the The VAT Act provides more insight The VAT Act provides
specifies the exemption foreign tax credit of on some of these exempted more insight on some
conditions necessary applies to a a taxpayer for a year supplies of these supplies
to qualify for these person who of income shall not
allowances. has regularly exceed the
• The Act provides for complied with Ugandan income tax
other tax allowable their tax payable on the
expenses but subject obligation for taxpayer’s foreign-
to fulfilment of the at least a source income for
Good to period of three that year.
know conditions therein.
years • Separate
computations are to
be made for foreign-
sourced income for
which the credit
applies and the
other income from
foreign sources.

Uganda (cont.)
VAT Deferment VAT (exempt supplies) VAT (zero rated supplies)
Minimum The VAT to be deferred Not applicable.

Investment should be more than
required USD 4,000.
The VAT which is VAT is exempted from the supply of; The following supplies are
payable at importation • social welfare services; zero rated;
is deferred for • Export of goods or services
• financial services from Uganda as part of the
• education services supply;
• burial and cremation services; • international transport of
• betting, lotteries and games of chance goods or passengers and
tickets for their transport
• passenger transportation services (other than Tour
• drugs and medicines
and Travel operators)
• seeds, fertilizers,
• dental ,medical and veterinary goods pesticides, and hoes;
• photosensitive semiconductor devices, including • sanitary towels and
photo-voltaic devices, whether or not assembled in tampons and inputs for
modules or made into panels; light emitting diodes; their manufacture.
solar water heaters, solar refrigerators and solar • educational materials
cookers • leased aircraft, aircraft
• life jackets, lifesaving gear, head gear and speed engines, spare engines,
governors spare parts for
• machinery, tools and implements suitable for use • aircraft and aircraft
only in agriculture maintenance Equipment.
• Cereals grown and milled in
• postage stamps
Uganda.
Maximum • unimproved land
benefit
• life, health, micro and re-insurance insurance
available
services;
• unprocessed foodstuffs, unprocessed agricultural
products
• veterinary, medical, dental and nursing services
• precious metals and other valuables to the Bank of
Uganda for the State Treasury
• by way of sale, leasing or letting of immovable
property, other than;
(i) a sale, lease or letting of commercial premises
(ii) a sale, lease or letting for parking or storing cars
or other vehicles;
(iii) a sale, lease or letting of hotel or holiday
accommodation;
(iv) a sale, lease or letting for periods not exceeding
three months; or
(v) a sale, lease or letting of service apartments
• petroleum fuels subject to excise duty,(motor spirit,
kerosene and gas oil), spirit type jet fuel, kerosene
type jet fuel and residual oils for use in thermal
generation to the national grid.
Type of
Tax deferment Tax exemption Tax exemption
benefit
Training
N/A
Benefit
This facility is available The VAT Act provides more insight on some of these The VAT Act provides more
for imports of Plant and exempted supplies insight on some of these
Machinery for use in supplies
Good to know the production of
taxable goods

Uganda (cont.)
Double
Tax on International Duty draw back for Manufacture under
Taxation Duty Remission
Payments exporters bond
Agreements
Minimum
Investment None
required
Interest paid by a Uganda has Customs undertakes The Council of Ministers of the East Manufacturer can
resident company to a Double to refund all or part of African Assembly has powers to apply to the
non-resident person in Taxation any import duty paid grant a remission of duty on goods Commissioner to be
respect of debentures is treaties with on material inputs imported for the manufacture of issued a license to
exempt from tax United imported to produce goods in a Partner State. hold and use
kingdom, for export or used in imported raw
Zambia, a manner or for a materials intended
Denmark, purpose prescribed Some of the goods currently for manufacture for
Norway, as a condition for considered include; export in secured
South Africa, granting duty draw  90% remission on sugar for places without
India, Italy, back. industrial use imported by payment of taxes
Netherlands Manufacturers.
and Mauritius.
Maximum Duty may be  100% remission on Inputs for
benefit refunded on raw the manufacture of exercise
available Entities that materials imported books and other essential
are domiciled and used on the goods;
in these goods locally Stranded wire used in
Countries produced for export. manufacture of tyres- Treads for
enjoy a cold retreading used in the
reduced rates retreading of tyres;
of
Withholding Packaging Materials for use in
tax subject to the manufacture of goods for
the conditions export;
therein. Raw materials for use in
manufacture of aluminum cans
for the dairy industry.
Type of
Tax exemption Tax reduction Tax exemption Tax deferment
benefit
Training
N/A
Benefit
This exemption only The benefit is The claimant has to An investor can apply to the council It makes available
applies where the available only show that the of ministers to be considered for working capital,
debentures were issued where the products were duty remission their operations are which would have
by a company outside recipient of exported in line with government policy been tied up through
Uganda for the purpose the income is paying duties
of raising a loan outside the beneficial immediately after
Uganda; the debentures owner and importation.
were widely issued for possesses
the purpose of raising economic
Good to funds for use by the substance in The annual license
know company in a business that country. fee for a bonded
carried on in Uganda or factory is $1,500 per
the interest is paid to a calendar year or on
bank or a financial pro rata basis if
institution of a public issued within a
character; and the calendar year.
interest is paid outside
Uganda.

Uganda (cont.)
National Social
Carry Forward Stamp Duty
Free Trade Zone 0% Import Duty Security Fund
Losses Exemption
Obligations
Minimum
Investment Adequate capital None None
required
All goods entering a Investment in any of the listed The tax law in Exemption from the The Managing
free port zone shall sectors will generally afford Uganda provides requirement to pay Director of the
be free from import various duty exemption for unlimited carry stamp duty on Fund may exempt
duties and taxes, will regimes subject to the forward of transfers between any employer who
be considered to be restrictions in the law; assessed tax associated applies to him or
outside the customs  Aircraft operators losses subject to companies her from payment
territory of Uganda the restrictions of a standard or
and will not be  Ships and Other Vessels therein. special contribution
subject to the usual  Manufacturers or both in respect
customs control.  Hotel, Tourism and Tour of an employee
operations employed by such
 Hospitals, clinics and employer subject to
Maximum Uganda has already the conditions in
diagnostic laboratories
benefit started the law.
available operationalizing the  Mining and petroleum
first free zone. The operations
Law and regulations  Agriculture sector
that shall govern the  Education
zone are already  Security
operational.
 Transport
 Importers of goods
originating from COMESA
region
 Importers of goods
originating from the East
African Community.
Type of
Tax reduction Tax deduction Tax exemption Tax exemption
benefit
Training
N/A
Benefit
The company must It is important to approach The general right to This exemption is This exemption is
be registered for the a tax advisor for details on carry forward tax subject to available where the
sole purpose of the particular items which losses indefinitely is limitations in the employee is not
operating a Free Zone enjoy 0% import duty. restricted where, law and clarity need ordinarily resident
in Uganda; during a year of be obtained from a in Uganda, and is
The company must income, there has tax advisor for liable to contribute
have an adequate been a change of proper guidance on to the Fund.
equity base or able to 50% or more in the how to make us of Secondly such a
access capital to underlying ownership this exemption person contributes
enable it develop a of a company, as to another scheme
Good to compared with its
Free Zone or operate outside Uganda
know ownership in the
in a Free Zone; with similar
previous year. characteristics with
The intending
investor who seeks the Fund.
the license to operate
in a Free Zone must
be commercially
viable and must be
based on a suitable
and credible business
plan;

Central Africa
Ouarzazate
Solar Power
Plant in
Morocco
Chad
Tax incentive
Tax reduction for investments
Minimum Investment required Minimum 60 Million FCFA.
40% of the invested amounts shall be deducted from the taxable base
Maximum benefit available
for personal income tax and corporate income tax.
Type of benefit Tax reduction
Timeframe Investors have a two years deadline to realize the investment.
Good to know Delay in processing to be expected.

Democratic Republic of Congo
Tax incentive (Table 1)
Regime applicable to strategic
Common regime
Mining regime (Law N° 007/2002) partnership on the value chain
(Law N°004/2002)
(Decree N°13/049)
Minimum
Investment US$ 10 000 Not applicable US$ 15 000 000
required
 Exoneration on CUSTOMS ADVANTAGES :
benefits and profits;  Suspension of the value-added tax
 Exoneration of the  Total exoneration of all customs rights on the in interior regime as well as on the
fundamental tax on exportation of salable products (in relation with importation, on the materials and
the built and non-built the mining project); building materials, on equipment,
surface areas used  Payment of the expenses and royalties in spare parts, inputs and the raw
for the project of remuneration for the services returned on the materials destined exclusively to
investment ; exportation of salable products or goods of the project ;
 Exoneration of the temporary exportation for perfection, but in the  Suspension of the value-added tax
entry rights of limit of 1% ; on the benefits of service done in
equipment and other  Customs Rights of 2% on goods having a strictly the setting of the exploitation
materials ; mining vocation before the effective exploitation bound directly to the project.
 Exoneration of exit of the mine, and 5% after ;  Suspension of the value-added tax
rights of finished  Customs Rights of 3% on fuels, lubricants, on the intermediate products
products ; reactive and edible destined to the mining and/or finished, as well as on the
 Exoneration of activities, during the whole length of the project ; benefits of services produced by
proportional rights at - Temporary admission exempt of customs for 6 the company ;
Maximum the time of the months (extendable 2 times) on the imported  Exoneration of the rights and taxes
Benefit constitution of the equipment destined to be re-exported. at the importation of goods, inputs,
available corporation and the FISCAL ADVANTAGES : raw materials and equipment
increase of the share destined for the project ;
capital to finance the  The buildings situated inside of the mining  Knocking off of the taxes collected
approved project. concessions are not submitted to the land tax ; by the initiative of the different
NOTE: The investor is  The vehicles used exclusively within the mining ministries and taxation services at
held to pay for the project are exonerated of the tax on vehicles and the central, provincial and local
administrative tax of 2% the special tax of road circulation ; levels by way of interdepartmental
at the time of the  The interests paid on the loans in foreign decree ;
importation of the currency are exonerated of the income tax; the  Lightening of the costs of the
equipment and materials dividends are imposed to the rate of 10% ; remuneration for some benefits in
and the VAT of 16%.  The rate of the tax on the benefits and the profits the institutional setting ;
This tax is repayable by are of 30% ;  Eligibility to the statute of
the Government Tax  The rate of the Exceptional Tax on privileged partner vis-à-vis fiscal
Authority (DGI) or Remunerations of Expatriate (IERE) is of 10% in services ;
recoverable for the matters of mining. Otherwise, the lERE is here a  Application of the preferential
companies that collect deductible load of the tax on the benefits and tariffs of energy by kilowatt/hour.
the VAT. profits (IBP).
Type of
Tax reduction
benefit
Training
Not applicable
Benefit

Democratic Republic of Congo (cont.)
Tax incentive (Table 1 - continued)
Common regime Mining regime (Law Regime applicable to strategic partnership on the value
(Law N°004/2002) N° 007/2002) chain (Decree N°13/049)
Duration of benefits:
 Economic region A
(Kinshasa): 3 years as
from the signing of the
interdepartmental
decree of approval of
the project for the right
of entry and the There is no limit to
property tax, and from the duration of the The length of the fiscal and customs advantages is of four
How to claim / the beginning of benefit available, (4) years.
Timeframe exploitation for the provided the company It can be extended following the importance of the
corporation tax ; complies with its investments and their amortization programme.
 Economic region B obligations.
(Bas Congo,
Lubumbashi, Likasi and
Kolwezi) : 4 years ;
 Economic Region C
(other Provinces, cities
and towns of the
country): 5 years.
The above mentioned incentive as per the decree, are
subject to the conditions below for them to be maintained :
1. Increase and maintain production and products derived
during the period of economic promotion of the industrial
Approval frequency: unit in the context of investment; increase and maintain its
production equipment in good working conditions and
Only once, except for the develop the network of local suppliers through local
projects to be organizations in order to ensure income distribution on all
implemented in different the value chains and throughout the territory concerned by
production sites or of the project;
different nature. The
Visit 2. Make efforts to rationalize its management and increase
investor is held to pay for
https://www.mines- its productivity in order to reach the comfort zone and to
the administrative tax of
rdc.cd/fr/ to download pass positive results at the end of the duration of
Good to know 2% at the time of the
the mining code and preferential tax and customs advantages;
importation of the
others important
equipment and materials
documents. 3. Ensure its contribution to the national economy for the
and the VAT of 16%.
national economy for its tax obligations, when the benefits
This tax is repayable by the are terminated;
Government Tax Authority
4. Propose and implement a plan of supervising producers
(DGI) or recoverable for the
so that production meets international standards;
companies that collect the
VAT. 5. Ensure that the maximum available local raw materials is
obtained with the objective of reaching 70% of stock of the
supply at the end of the first exemption;
6. Payback to the community in the form of social
investments, the gross operating margin.

Democratic Republic of Congo (cont)
Tax incentive (Table 2)
Regime applicable to Electrical
Regime applicable to Agriculture sectors (LAW n0 11/022)
energy sectors (Decree n° 15/009)
Minimum
Investment Not applicable
required
Charges bound to the maintenance of the road that connects the
concession of the agricultural operator to the public highway are tax
base-deductible ;
- Agricultural operators benefit from a preferential tariff in the
consumption of water, electric energy and the oil products ;
- Self-generated water and energy aiming at agricultural exploitation
is exempt of all taxes and duties ;
 Suspension of customs duties and
- The industrial agricultural operator is allowed to constitute in value added tax on import of
exemption of tax, a provision not exceeding 3% of the turnover of equipment, material, tools and
the exercise for the rehabilitation of exploitable arable land, and the spare parts;
Maximum prevention of major risks and agricultural calamities. This provision is
used in the time limit of two years or if not available it is restored in  Suspension of customs duties and
Benefit available
the tax base of the year that follows the expiration of the above- value added tax on import of
mentioned time limit : - With the exception of administrative electrical energy;
royalties, the agricultural importation inputs designated exclusively to
 Export of energy is submitted to
the agricultural activities are exonerated of the duties and taxes at
1% rate
the importation; - Agricultural products are exonerated of duties and
taxes at the exportation ;
- Royalties and expenses in remuneration for the services returned
by public organisms working at the borders cannot exceed 0.25% of
the value of the exported products ; - Built and non-built surface
areas affected exclusively to the agricultural exploitation are
exempted of the property tax ; - The Tax exemption of all rolling
stock affected exclusively to the agricultural exploitation.
Type of benefit Tax reduction/ tax exemption
How to claim / The benefit is available for the timeframe as specified in the contract The benefit is available for a duration
Timeframe between the beneficiary and the state. of 4 years.
The corporate income tax is charged at the normal rate (35%) while
Good to know
the CIT for a family is charged at 20%

Republic of Congo
Tax incentives are grouped in two main categories : The Preferential Regime and, The Incentives Regime
cover activities such as farming, mining, industrial, commercial and service in respect of the laws and
regulations of the country.
The conditions to the eligibility are various and among them there is the creation of permanent employments
which operate at least 280 days per year.
THE PREFERENTIAL REGIME
General Regime “R” Special Regime “S” Preferred development area
[XAF 30,000,000 – XAF

Investment required XAF 100,000,000 N/A*
100,000,000]
During The Setup Phasis (Duration: The entire setup phasis + The first 3 years of operation)
 Customs benefits applicable to export activities

 Suspension of customs duties for activities concerning the research of natural resources ;
 Reduction of 50% of registration fees for creation of companies, capital increase,
companies’ merger, transfers of share etc.
Benefits
During The Operations Phasis (Duration: 3 years from the end of the Setup Phasis)
 Exemption of Corporate tax or, Tax on personal income

 Permission to proceed with degressive/accelerated amortization
 Permission to defer negative results on the 3 following exercises
 Application of VAT at 0% rate on exported goods
*Although a Preferred development area regime is mentioned in the Investment Charter, it is not yet applicable in Congo
THE INCENTIVE REGIME

INCENTIVE FOR EXPORT INCENTIVE FOR INCENTIVE FOR INCENTIVE FOR CULTURAL
REINVESTMENT CREATIE/ACTIVITIES IN AND SOCIAL INVESTMENT
DIFFICULT ACCESS ZONE
 Be approved for Regime

Perform new investments of  Create a new company
Export at least 20% of the G or S
Conditions at least 1/3 of the existing  Be approved for Regime
production  Perform social and
fixed-assets G or S
cultural investment
 Customs benefits
applicable to export
activities
Tax allowance of 50% Tax allowance of 50%
 Exemption on the export Tax relief for social and
Benefits applicable on Corporate / applicable on Corporate /
of manufactured goods cultural investment
Personal Income Tax Personal Income Tax
 Application of VAT at the
0% rate for exported
goods
Three Years (from the
Two Years (from the To define by a Ministerial
Duration N/A completion of the
company’s 3rd year) Decree
investments)

São Tomé and Príncipe
The Investment Projects carried out under this benefits are irrevocable during the period of its duration,
cumulative with any others of a financial nature and are subject to the conclusion of an Administrative
Investment Agreement.
General Tax Incentives

Customs Duties Income Tax Modernization and Introduction of New
Technologies
Minimum € 50,000.00 / € 50,000.00 / € 50,000.00 /
Investment € 250,000,00 / € € 250,000,00 / € 250,000,00 /
required 5,000,000,00 € 5,000,000,00 € 5,000,000,0
• The amount invested in specialized
• 50% or Total equipment and in state-of-the-art
exemption from technology for the development of
payment of import • Investments carried out for the authorized business activities, shall
duties on goods and purpose of developing new benefit during the first five (5) years,
equipment intended to activities are subject to a 10% from the date of commencement of
launch new activities or Corporate Income Tax (IRC) activity, of a deduction to the taxable
Maximum expansion of any over the taxable income or over
Benefit available income for IRC purposes, up to a
ongoing activity. 50% of the taxable income maximum of 50% of the taxable
• The applicable • The applicable exemption income’s amount.
exemption depends on depends on the amount of • The applicable deduction is reduced to
the amount of minimum investment required. up to 25% if the investment is between
minimum investment € 50,000.00 and € 249,999.00.
required.
Type of benefit Tax Deduction
Training Benefit Not Applicable

Only applicable if the
goods to be imported are
not produced within • The normal Corporate Income
The same deduction shall apply, under the
national territory or, if Tax rate is 25%.
same conditions, on Personal Income Tax
being produced, do not • The start of operations is the
Good to know (IRS), but only in relation to income from
meet the quality / price time at which the operations to
activities belonging to category B (Business
requirements and the obtain income giving rise to
and Professional Income).
specific characteristics and taxation are commenced.
functionality required for
the investment project.

São Tomé and Príncipe (cont.)
General Tax Incentives (continued)
Training Stamp Tax Incentive Sisa Tax Exemption
€ 50,000.00 / € 50,000.00 / € 50,000.00 /

Minimum Investment
€ 250,000,00 / € 250,000,00 / € 250,000,00 /
required
€ 5,000,000,00 € 5,000,000,00 € 5,000,000,00
The costs related to professional
Amendments to the local
training of São Tomé employees’
company’s by-Laws shall be Total exemption of Sisa Tax (Real
Maximum Benefit shall be deducted from the
exempted from stamp tax during Estate Transfer Tax) regarding the
available taxable amount for the purposes
the first five years counted from immovable property acquisition.
of calculating IRC, when related to
the beginning of the operations
authorized ventures.
Type of benefit Tax Deduction Tax Exemption
Training Benefit Yes Not applicable Not applicable
Good to know Not Applicable
Agriculture, Agro-industry, Livestock and Fishing Tax Incentives

Customs Duties Income Tax Modernization and Accelerated Training
Introduction of New Depreciation Benefit
Technologies
Minimum
Investment €50,000.00 €50,000.00 €50,000.00 Not applicable €50,000.00
required
The amount invested in
• Full exemption from specialized equipment
import duties on and in state-of-the-art
goods and technology for the An accelerated
equipment intended The costs related to
The investments in development of depreciation is
exclusively for the professional training
these areas authorized business allowed regarding the
implementation of of São Tomean shall
benefits, in the first activities, shall benefit investments made in
Maximum the project. be deducted from the
seven (7) years during the first five (5) the Tourism,
Benefit taxable amount for
• Full exemption from after its years, from the date of Education, Health and
available the purposes of
export duties implementation, commencement of New Technologies
calculating IRC, when
regarding export and from a 50% IRC activity, of a deduction sectors and in any
related to authorized
re-export operations rate reduction. to the taxable income other export-oriented
ventures.
of products for IRC purposes, up to sectors.
generated by the a maximum of 50% of
investment the taxable income’s
amount.
Type of Accelerated
Tax Deduction Tax Deduction
benefit Depreciation
Training
Not Applicable Yes
Benefit
At the end of the The same deduction
term, the new shall apply, under the
projects will still be same conditions, on
Upon approval by the
entitled, during two Personal Income Tax
competent authority of a
Good to (2) years, to a 25% (IRS), but only in
provisional list to be Not Applicable
know reduction of taxable relation to income from
submitted to the
income, and activities belonging to
Customs Directorate.
subject to a 10% category B (Business
Corporate Income and Professional
Tax (IRC). Income).

Tourism and Hospitality
Customs Duties Income Tax Reinvestment Accelerated Training
Depreciation
Benefit
Minimum
Investment €50,000.00 €50,000.00 €50,000.00 Not applicable €50,000.00
required
The rehabilitation, • The reinvested capital
construction, expansion or benefits from a deduction An accelerated
Investments to the taxable amount of
modernization of hotel units depreciation is
carried out 30% of the value of the The costs related to
and their complementary or allowed regarding
for Tourism profits invested in the professional training
related parts, which main the investments
and financial year up to the of São Tomean shall
purpose is the production of made in the
Maximum Hospitality fifth financial year be deducted from the
tourism services, as well as Tourism,
Benefit purposes are following reinvestment taxable amount for
the development of rural and / Education, Health
available subject to a the purposes of
or ecological tourism shall • Applicable only to and New
12% calculating IRC, when
benefit from an exemption projects creating at least Technologies
Corporate related to authorized
from import duty on goods and twenty (20) jobs, and for sectors and in any
Income Tax ventures.
equipment intended a period of seven (7) other export-
(IRC).
exclusively for the years from the oriented sectors.
implementation of the project. exploration’s start.
Type of Accelerated
Tax Deduction Tax Deduction
benefit Depreciation
Training
Not Applicable Yes
Benefit
• The reinvestment is the
application, in whole or in
The investments on part, of net profits
rehabilitation, construction, obtained in an after-tax
expansion or modernization of period in the expansion,
barns, lawns, casinos and diversification or
other similar units when not modernization of installed
Good to added to any of the units Not capacity. Not Applicable
know previously referred, car rental, Applicable
travel agencies, tour operators • Upon the expiration of
and alike are excluded of the the 7 year period, the
mentioned tax benefits, being new enterprises covered
able to benefit from the ones by this benefit are
mentioned on table 1. entitled to a 10%
Corporate Income Tax
(IRC).

Special Benefits
Large-scale projects Special Development Areas
Minimum
Investment USD 10,000,000.00 € 50,000,00
required
• Ventures and infrastructure projects of New developments located in the geographical areas
public interest carried out under a called Special Development Zones (ZED), and
Concession, may benefit from exceptional depending of the activity may benefit from the
incentives, regarding import duties, following:
Maximum Benefit withholding tax, IRC or IRS, Stamp Duty
available • Customs Duty Exemption;
• Reinvestment, among others.
Type of benefit Tax Deduction
Training Benefit Not Applicable

• To be granted by the Council of Ministers, These benefits are granted by the Government through
on a proposal from the Minister responsible administrative investment contracts and are not
for the area of Finance and upon the cumulative with other benefits
conclusion of an investment agreement
between the State and the promoter of the
project, to be approved by the Council of
Good to know Ministers, which will set the scope and
objectives of the incentives to be granted
and the penalties for non-compliance by the
promoter.
• Applicable for a seven (7) years from the
implementation period, tot being cumulative
with other benefits.

Northern Africa
Ouarzazate
Solar Power
Plant in
Morocco
Egypt
Tax incentives
Incentives under the investment Law No. 8 for 1997
• No limitation/restrictions for foreign investors ownership after obtaining security clearances from the national
security agencies (and they have to pay the value of their shares in the company in foreign convertible
currencies );
• Unless for some specific sectors are restricted (i.e. Importing for the purpose of trading in Egypt require 51% at
least Egyptian participation, Acting as a commercial agent) and;
• Locations restricted (i.e. Sinai Governorate, however doing business in Sinai and certain strategic area require
55% at least Egyptian participation and a prior approval from the relevant authorities.).
• The companies and establishments shall not be nationalized or confiscated.
• Sequestration shall not be imposed administratively on the companies and establishments nor shall their
property and funds be distained, seized, retained in protective custody, frozen or confiscated.
• No administrative quarter shall interfere in pricing the companies and establishments’ products, nor in
determining their profits.
• No administrative quarter shall cancel or stop the license granted for using the realties of which the usufruct
rights is licensed to the company or the establishment wholly or partially, except in case of infringing the license
conditions.
• The companies shall have the right to possess and own building lands and built realties as necessary for
exercising their activities and expanding them, whatever the nationality or place of residence of the partners, or
the percentage of their partnership.
• The companies and establishments shall have the right to import by themselves or via third parties whatever
Overall they need for their establishment, expansion or operation, comprising production inputs and requisites,
Summary of materials, machines, equipment, replacement and spare parts, and means of transport as suitable to the nature
Country of their activities, without need for recording in the Register of Importers.
Information
• The companies and establishments shall have the right to export their products by themselves or through
middlemen without being licensed therefore and without need for recording themselves in the Register of
Exporters.
• The imported machinery and equipment necessary for establishment the project shall be subject to flat rate of
2% of the value.
• The labour -intensive investment projects, the projects that are trying to intensively use the local component in
their products, the projects that invest in the field of logistic services or internal trade development, electricity
(production , supply and distribution thereof) e.g. traditional energy, new and renewable energy, agriculture
projects, land , maritime , rail-ways transportation projects, or the projects that hold investments in remote areas
and less favoured regions intended for development , shall be granted facilities and additional non-tax
incentives, including:
o Authorize the establishment of special custom outlets for the exportations and importations of the
investment project in agreement with the Minister of Finance.
o Grant discounted prices or facilitations in the settlement of the value of the used energy.
o Refund the value of supplying utilities to the land allocated for the investment project or a part thereof to the
investor after operating the project.
o Charge part of the cost of the employees’ technical training to be borne by the government.
o Charge the employee’s share and the employer’s share in the social insurance or a part thereof, for a certain
specified period, to be borne by the government.
o Dispose land and real estates solely owned by the government or those owned by public corporate bodies.

Libya
Tax Incentives
Incentives under the Law 9 of 2010 Incentives under Free Trade Act of 2000
Minimum
The Investment Authority Committee shall determine the
Investment No minimum is required.
minimum capital that conforms with the nature of the activity.
required
 Exemption from customs duties, import fees, service

charges and other fees and taxes of a similar nature on the
importation of machinery, equipment;
 Exemption from all fees and taxes for a period of 5 years,
on facilities, spare parts, transport means, furniture,
requirements, raw materials, publicity and advertising
items, related to the operation and management of the Projects and incomes resulted in free zone whether
project; by natural persons or companies are exempted from
Maximum  Exemption from CIT for a period of 5 years; tax and fees. Are also exempted from tax and duties
benefit all the transactions, assets, loans, cash transfer and
 Exemption of the returns of shares and equities, arising
available credit movement in the free zone. This exception
from the distribution of the investment project’s interests;
does not break right of authority, that provide service
 Exemption from interest arising from the project’s activity of facilities in the free zones, to get a return.
if re-invested;
 Exemption from all documentary records, registers,
transactions, agreements that are made, ratified, signed or
used by the investment project, from the stamp duty; and
 Carry-forward of losses sustained within the exemption
period to subsequent years.
Type of
Tax exemption
benefit
Training
None
Benefit
Other incentives are available, subject to a decision from the
Investment Authority Committee, to offer for the investment
projects, tax privileges and exemptions for a period, not  All projects, funds and goods in transit owned
exceeding 3 years, or other additional privileges, if those by the investors and users in the free zone, are
projects prove that: considered private funds whatever is the owner,
Good to and can not be seized only by law or an
• They contribute to the achievement of food security. effective judicial instruction in Libya.
know
• Utilize measures that are capable of achieving abundance  It is not allowed nationalize, confiscate, divest
in energy or water or contribute to environmental the projects based in free zones except by law
protection. and with a fair compensation.
• Contribute to the development of the area.

Morocco
Tax Incentives
Entities established in Specific incentives Export Promotion Business activities
Casablanca Finance granted to important and hotel within Export free zones
City projects incentives (EFZs)
Investments exceeding
Minimum A minima of the turnover
100 Million MAD (Other
Investment with foreign companies None
criteria are taken into
required between 20% and 60%.
account).
• National or international
headquarters are
subject to reduced
corporate tax at a rate
of 10%; • Up to 20%
• Profit relating to export participation of the
turnovers are fully Government in the
expenses (i.e. external • Profit relating to • Exemption from CIT for
exempt from CIT
infrastructure export turnovers the first 5 years and
during the first 5 years
expenses, land are fully exempt applicable rate of 8.75%
of operations and
Maximum acquisition, vocational from CIT during the for the following 20
subject to 8.75% for
benefit available training); first 5 years of years; and
the following years;
operations. The • Exemption for the
• Gross salaries and • Exemption from
applicable CIT rate dividends paid to non-
wages paid to customs duties on
is 17.5%. residents.
employees are subject equipment imported;
to income tax on and
salaries at a rate of • Exemption from VAT.
20% during 5 years;
and
• Foreign exchange
facilities.
Tax exemption, Cash

Type of benefit Tax reduction Tax exemption
grant
Yes.Contribution to
Yes. Contribution to
professional training
Yes. Contribution up to professional training costs
Yes. Refund of part of costs may be
Training Benefit 20% for professional may be available
vocational training. available depending
training costs. depending on the sector of
on the sector of
activities
activities.
• Need to apply for pre-

approval before
company is • Need to apply for pre-
incorporated. approval before
company can claim.
• Casablanca Finance
City (“CFC”) is a • The incentives are Need to apply for pre-
Good to know financial area governed granted to N/A approval before company
by the law 44-10 where important investments can claim.
financial and non- under an agreement
financial companies signed with the
carrying out national or Government.
international activities
can be located.

Tunisia
Tunisia has adopted in September 2016 a new investment law which sets out the legal statutory regime of
investment made by individuals or legal persons, Tunisians or foreigners, residents or non residents in all
economic activities. The tax incentive system, adopted in February 2017 and applied since 1st April 2017 is
devoted to sectors of national interest such as agriculture, regional development, export, support activities
and technological and innovative investment
Tax Incentives
Tax incentives for fully Regional Technology and Agricultural
General Tax
exporting companies developments research Promotion Developments
incentives
(Industry and services) Incentives Incentives Incentives
None, but a
minimum of None, but a
None, but a minimum
equity ranging minimum of equity
of equity ranging
between 10% or of 10% or 30% of
Minimum between 10% or 30% None, but a minimum of equity ranging between
30% of the the investment
Investment of the investment costs 10% or 30% of the investment costs is required
investment costs costs is required
required is required (depending (depending on the category of the investment).
is required (depending on the
on the category of the
(depending on category of the
investment).
the category of investment).
the investment).
• Depressive • Reduced Corporate • Bonus 50% up to

300KD for investment • Tax exemption on
Income tax Income Tax rate of
in Applied Research reinvested
rate during the 10% on export
and Technology profits;
four first years profits; • Income tax Laboratories, patents • Full tax
• Customs • Full exemption from exemption on profits
• Bonus 50% up to exemption for the
duties corporate tax on for 10 or 5 years
300KD for projects 10 first years of
exemption on reinvested profits; depending on the
with clean operation;
importation of regions and a
• VAT and Customs technologies
equipment; reduced Corporate • VAT suspended
duties exemption on
Income Tax rate of • Bonus for energy on imported
• VAT limited to importation of the
10% on export saving investment and capital goods that
6% on goods and products,
Maximum profits; development of have no locally-
importation of necessary for the
benefit renewable energies: made similar
equipment; export activities of the • Income tax
available Bonus generally counterparts; and
and company; exemption on
reinvested profits; ranging between TND • State
• VAT • Local VAT suspension 2500 and TND 500 Contribution may
Suspension on any purchases of • Exemption of some 000 (generally also apply to
and goods and services payroll taxes; and between 20% to 70% infrastructure
consumption required for the of the investment);
• Social security expenses to
duty on the export activity of the contribution • Reduction of Customs develop areas
local entity; exemption of 100% duties to the rate of meant for fish
acquisitions of
• VAT zero rate on their for 10 or 5 years. 10% or full exemption farming and for
equipment
exports; and (depending of the cultivation using
during the
• Exemption of payroll investment); and geothermal
period of
taxes. water.
investment • VAT Suspension. .

Tunisia (cont.)
Tax Incentives
Tax incentives for
fully exporting Regional Technology and Agricultural
General Tax
companies developments research Promotion Developments
incentives
(Industry and Incentives Incentives Incentives
services)
Type of
Tax exemption Tax exemption, Tax reduction Tax exemption
benefit
Full or partial coverage
Training
None by the State of training None
Benefit
staff costs.
 An application
process
submitted to
The Tunisian
Investment
An application Authority or APII
process submitted (Agency for the
to The Tunisian Promotion of An application
Investment Industry and process needs to
Authority or APII Innovation) be followed with
An application
(Agency for the needs to be An application process the Tunisian
process needs to be
How to claim Promotion of followed with needs to be followed Investment
followed with the
/ Timeframe Industry and the Tax with the competent Authority or APIA
competent
Innovation) needs authorities authorities. (Agency for
authorities.
to be followed mainly for the Agricultural
with the Tax VAT Investment
authorities mainly suspension Promotion)
for the VAT
suspension.  Time frame of
10 Years for the
reduced
Corporate
Income tax rate
incentive.
The Tunisian Investment Authority or
APII (Agency for the Promotion of
Good to The granting of the national social security incentives may take three
Industry and Innovation) generally delivers
know months.
the decision granting the incentives within
one month.

Western Africa
Gas flair:
Niger Delta
Nigeria
Cameroon
Tax Incentives
Incentives for Industrial Free
Stock Exchange Youth employment
PPP Contracts private Zone & Special
sector promotion
investments Free Zone
None, but need to
Minimum
5 million to 25 carry out its activities
Investment None.
Million XAF under the free zone
required
regime.
• Tax reduction of
20% for a period
of three years for
capital increase
• Registration free
representing 20% • Firms falling under
of charge for
of the share the actual earnings
deeds and Exoneration from
capital; tax system which
conventions VAT, reduced rate of
• Tax reduction of recruit
entered into during 5% on custom
25% for a period Cameroonian
the first 5 years of duties, 50%
of three years for graduates below Tax exemption over
Maximum the exploitation reduction on
spin-offs 35 years for first- the first ten years of
benefit phase, and 5% registration duties,
representing 20% time jobs on open- operation, customs
reduction in the 50% to 75%
Available of the share term contract exemptions on
CIT rate; reduction on CIT,
capital; and basis shall be exports.
• VAT is borne by 50% to 75%
• Tax reduction of exempted from
the public entity; reduction on tax on
28% for a period taxes and
and income from stocks
of three years contributions on
• Taxes and custom and shares.
from the date of the salary paid to
duties is borne by
listing for capital such youths.
the public entity.
increase or spin-off
representing less
than 20% of the
share capital.
Type of Tax exemption/ Exemption from
Tax reduction Tax exemption
benefit reduction direct taxes
Training
None
Benefit
• Delays in
processing are
• Effective 1 January more frequent.
2012. • In addition,
• Possibility of • This measure shall approval may be
cumulating the apply with effect denied to an
Good to Delay in processing stock exchange from 1 January investor in
N/A
know are more frequent. system with other 2016 and shall be competition with
systems such as valid for a three (3) one or more other
reinvestment, year period. investors
public-private benefiting from
partnership. the incentives,
provided that the
investor qualifies.

Ghana
Tax Incentives
Tax incentives Incentives Location incentives
(available to available to (manufacturing General investment incentives
Ghana free zones
companies in companies companies on registration with the Ghana
(industrial zones/
specific industries engaged in agro- excluding agro Investment Promotion Center
freeports)
for specified processing and processing/cocoa (GIPC)
number of years) cocoa by-products by-products)
Generally, there is no minimum capital requirement to start No minimum capital • For Joint Ventures with
business in Ghana. However a non-Ghanaian or foreigner desiring required. Ghanaian partners, a minimum
to do business in Ghana is required to register with the Ghana contribution of USD 200,000 in
Investment Promotion Council (GIPC) and comply with the cash or capital goods.
minimum investment requirements shown in last column. • For wholly owned foreign
Minimum
ventures, the minimum equity
Investment The minimum capital requirement, however, does not apply to is USD 500,000 in cash or
required Companies set up solely for export trading or manufacturing. capital goods.
• For trading companies, the
minimum equity is
US$1,000,000 in cash or capital
goods.
• Tax payable at the • New companies • 25% Tax rebate for • 100% exemption Automatic Immigrant Quota
rate of 1% of are taxed at 1% companies in the from direct and available:
chargeable income for the first 5 regional capitals; indirect taxes on all • For One expatriate when
for the specified years. and imports and equity invested is over
number of years • Subsequently, a • 50% Tax rebate for exports; US$50,000 and not more than
after which they 25% tax rebate if manufacturing • 100% exemption US$250,000;
will pay a standard located in the companies located from payment of • For Two expatriates when
rate of 25% CIT; regional capitals elsewhere. income tax on profit equity is over US$ 250,000 and
• The indicated of the country, for 10 years; not more than US$500,000;
number of years and 50% tax • Minimal customs • For Three expatriates when
Maximum varies for different rebate if located formalities; and equity is over US$ 500,000.00
benefit industries / elsewhere, • Total exemption and not more than
available sectors. (Refer applies. This does from payment of US$700,000; and
“Timeframe” not apply to withholding taxes • For Four expatriates when
below.) companies on dividends arising equity is more than
located in Accra out of free zone US$700,000.
and Tema. investments.
Special Incentives are negotiated
for identified strategic/major
Investments with a minimum
value of US$50,000,000 in
specified priority sectors upon
satisfying certain conditions.
Type of Tax rebate and Tax Tax exemption / Tax

Tax reduction Tax rebate Automatic Immigrant Quota
benefit reduction reduction
Training
None
Benefit

Ghana (cont.)
Tax Incentives (continued)
Location
General investment
Tax incentives Incentives available incentives
incentives on
(available to companies to companies (manufacturing Ghana free zones
registration with the
in specific industries for engaged in agro- companies (industrial zones/
Ghana Investment
specified number of processing and cocoa excluding agro freeports)
Promotion Center
years) by-products processing/cocoa
(GIPC)
by-products)
• The time frame
applicable for the
benefit differs for each
respective industry or
sector:
- Agriculture: 5-10 years
- Rural Banking: 10
years
- Waste Processing: 7 Refer “Maximum
How to claim/ Upon registration with
years benefit available” None First 10 years
Timeframe GIPC
- Real Estate (low above.
Residential housing):
5 years
- Approved Unit Trust
Scheme and Mutual
Fund, Venture Capital
Financing: 10 years
- Venture Capital
Financing: 10 years
• Unrealised losses can • The minimum capital

be carried forward for • A condition for the requirement does
between 3 to 5 years (5 grant of a free zone not apply to portfolio
years are for priority license is that the investment and an
sectors and 3 years for licensed entity must enterprise set up
all other sectors). export at least 70% solely for export
of its output. trading and
• Priority sectors are: manufacturing.
Mining and Mineral N/A • 30% output is
Operations; Petroleum allowed on the • Free transferability
Good to know
Operations; Energy and domestic market. of convertible
Power; Manufacturing; currency through an
Farming; Agro- • A free zone authorised dealer
processing; Tourism enterprise could be bank of capital,
and Information and wholly-owned by a dividend, interest
Communication foreigner. and fees net of all
Technology. taxes.
All Companies are entitled to an additional deduction based on wages and salaries paid to a fresh graduates employed
from recognised Ghanaian tertiary institutions. A deduction of up to 50% salaries and wages paid to the fresh graduates
is available where these persons form at least 5% of the entity’s entire work force.

Ivory Coast
Tax incentives are granted under two regimes, namely the declaration regime and the approval regime. The
Code provides for specific incentives available to eligible enterprise depending on the location of their
business site. For this purpose, the Ivorian territory is divided into three zones: A (Abidjan district), B (cities
with at least 60,000 inhabitants) and C (cities with less than 60,000 inhabitants and special economic zones).
Tax Incentives
Tax incentive under the Tax incentive under the investment Tax Incentives Special Taxation for free
General Tax Code code under the mining zone
code and the
Approval regime Declaration petroleum code
regime
No minimum
Minimum From XOF 200 investment is No minimum
At least XOF 10 million for No minimum investment
Investment million to XOF required to investment is
reinvestment is required
required 1 billion benefit from required
this regime
Through a
documented file
Through a
including a
Through a file to fill in with documented Through the
business plan Through the installation
How to details of investments file including a drafting of a
adressed to the of an entity and activities
claim addressed to the Director business plan petroleum or
CEPICI (centre de in the Free Zone area
of the tax offices adressed to mining contract
promotion des
the CEPICI
investissements
en Côte d’Ivoire)
Type of
Tax deductions
benefits
Tax reduction on industrial Exemption of Exemption of Exemption from : Total exemption for most
and commercial profits eligible companies eligible - VAT and, taxes.
reinvested in the activity in are as follows and companies are
Ivory Coast. mainly depend of as follows and - additional tax
the level of mainly depend imports There is only a specific
investment and of the area tax to pay, after 5 years,
for companies
Tax exemption provided for realisation of these where the based on the annual
purchases involved
companies set up for the investments : company is turnover (rate is 1%).
Maximum in exploration or
purpose of taking over situated:
benefit - 40% or 50% production of oil,
companies in a difficult
available reduction of - Corporate gas or minerals
situation.
customs duties income tax; and for mining
payable on the companies.
- Business
Tax exemption for profits importation of licence duty
derived from the the equipment and trading
exploitation of mineral used for licence
deposits. purpose of the duty;
project;

Ivory Coast (cont.)
Tax Incentives (continued)
Tax incentive under the Tax incentive under the investment code Tax Incentives Special
General Tax Code under the mining Taxation for
Approval regime Declaration regime code and the free zone
petroleum code
Tax exemption on gains - VAT; - Real estate tax; In addition to the A “royalty”
realised from the sale of fixed - Corporate income tax; - registration duty above, during the payment of
assets if reinvested within 3 on increase of the exploration and 2,5% of the
years. - Business licence duty exploitation phases, annual
and trading licence capital;
petroleum and mining turnover is also
duty; - 80% or 90% industries are exempt required.
Tax rate reductions available reduction of the from:
- Real estate tax;
for small and medium-sized employer
Maximum companies that register with - registration duty on contribution on - payroll tax;
benefit specific entities called increase of the capital; payroll taxes. - Corporate income
available “centres de gestion agrees”. tax;
(cont.) - Various rates reduction
of the employer - registration duties
contribution on payroll applicable to in-
taxes. kind or cash
share-capital
contribution;
- real estate tax.
Enterprises may apply for a The incentives under the The exemptions in Exemptions granted The Free zone,
reduction in tax on industrial approval regime are zone A are granted to the mining and named VITIB,
and commercial profits. granted according to the for 5 years; petroleum industries is located in
location of the business The exemption in may benefit to their Bassam near
site (zones A,B and C). zone B are granted subcontractors as the economic
The investment period must for 8 years; well. capital
not exceed two years. The exemptions in zone A The exemption in (Abidjan).
are granted for 5 years. zone C are granted
for 15 years ;
The reduction for reinvested The exemptions in zone B The free zone
profits is granted for profits are granted for 8 years. Companies eligible is limited to
reinvested in extension, for these exemptions biotechnology
diversification or The exemptions in zone C must keep regular and
modernization projects. are granted for 15 years. accounts under the communication
OHADA standards companies
Good to The exemptions are and will be assessed (NTIC) that
The reduction granted is must obtain a
know reduced by 50% up to 25% on actual profits.
capped at 35% for Abidjan licence issued
on the final 2 years before
zone and 40% for the others by the
the end of the exemption The exemptions are
region. company
periods. reduced by 50% up
to 25% on the final 2 called VITIB
These incentives may not years before the end SA.
be combined with sector- of the exemption
specific investment periods.
programs, such as those
for mining and These incentives may
hydrocarbons. not be combined with
sector-specific
investment
programs, such as
those for mining and
hydrocarbons.

Liberia
Manufacturing Energy Housing Exportation
Section 16(C) Section (C) Section 16(C) (Section 16)
The minimum The minimum

Minimum
The minimum investment capital required is investment capital investment capital
Investment
US$500,000.00. required is required is
required
US$500,000.00 US$500,000.00.
Maximum benefit The aggregate of up to 30% of the purchase price of the qualifying asset(s).
available (Section 204)
Type of benefit Incentive deduction
To request tax incentive certification, an investor must apply to the LNIC and the LNIC will conduct an
How to Claim/
evaluation of the certification request and will forward said request to the Minister of Finance &
Timeframe
Development Planning and maximal 15 working day for approval/rejection.
 A certified investment entitled to the special tax incentive is up to period of five (5) years subject to
continuing oversight.
 The incentive allows exemptions from GST and Import Duty of medical, educational and supplies
purchased in direct use or in connection with the investment activity intended to be placed in service
within a year, equipment and machinery, specialized vehicles, capital spare parts and other specialized
Maximum benefit
capital goods that are purchase for use directly in the investment activity and intended to be placed
available
into service immediately upon purchased, and automobiles, small trucks, and fuels are prohibited from
exemptions under this provision. Section 16.5(b)
 For investment exceeding USD$10 million and subject to the president and legislative approvals,
incentives may be allowed for period up to fifteen (15) years. Section 16.3 (C)

Liberia (cont.)
Information Banking Poultry Horticulture Agricultural – Small and
Technology (Section 16) (Section 16) (Section 16) food crop medium scale
(Section 16) cultivation and rubber and oil
processing palm
including cocoa cultivation and
and coffee processing
(Section 16) (Section 16)
Minimum
Investment The minimum investment capital required is US$500,000.00.
required
Maximum The aggregate of up to 30% of the purchase price of the qualifying asset(s).
benefit
available (Section 204)
Type of
Incentive deduction
benefit
Training
None
Benefit
How to To request tax incentive certification, an investor must apply to the LNIC and the LNIC will conduct an
Claim/ evaluation of the certification request and will forward said request to the Minister of Finance & Development
Timeframe Planning and maximal 15 working day for approval/rejection.
 A certified investment entitled to the special tax incentive is up to period of five (5) years subject to
continuing oversight.
 The incentive allows exemptions from GST and Import Duty of medical, educational and supplies
purchased in direct use or in connection with the investment activity intended to be placed in service within
Maximum a year, equipment and machinery, specialized vehicles, capital spare parts and other specialized capital
benefit goods that are purchase for use directly in the investment activity and intended to be placed into service
available immediately upon purchased, and automobiles, small trucks, and fuels are prohibited from exemptions
under this provision. Section 16.5(b)
 For investment exceeding USD$10 million and subject to the president and legislative approvals, incentives
may be allowed for period up to fifteen (15) years. Section 16.3 (C)

Nigeria
Tax incentives (Table 1)
Pioneer Status Work Employment Infrastructure Bonds & Companies Gas
Incentive (PSI) Experience Tax Relief Tax Relief Short Term engaged in utilization
Acquisition (ITR) Government gas utilisation incentive
Program Securities (Downstream program
Relief (bonds issued Operations) (Upstream
by corporate operations)
bodies and
supranational
also inclusive)
Minimum
Capital Minimum net
net
expenditure of employment
employment
Minimum not less than of 10
of 5 new
Investment N10 million to employees in None
employees,
required qualify for the the relevant
for a
pioneer status assessment
minimum of
incentive. period.
2 years.
• Tax free
period of 3
years
renewable • Gas income
for 2 years is subject to
or 35% tax at the
investment rate of 30%.
Exemption
• 3-5 year allowance.
from CIT up • Gas
income tax to 5% of transferred
Exemption CIT Gains from • Additional
holiday; assessable from a
from CIT up exemption of acquisition / investment
• Dividends paid to 5% of profit in the allowance of Natural Gas
30% of cost disposal and
out of pioneer assessable tax year to 15% (only Liquid (NGL)
Maximum incurred in interest
profits shall be profit in the which the where the facility to
benefit providing earned by
tax exempt profits relate company the gas-to-
available tax year in infrastructure holders of the
when but limited to chooses the liquids
which the or facilities of securities
distributed to company the gross tax free facilities is
a public above are tax
the emoluments period). subject to
qualifies. nature. exempt.
Company's paid to 0%
qualifying • Accelerated Petroleum
shareholders.
employees. capital Profits Tax
allowance. and 0%
royalty.
• Tax free
dividend
during the
tax free
period.

Nigeria (cont.) Tax incentives (Table 1 – continued)
Pioneer Status Work Employment Infrastructure Bonds & Companies Gas utilization
Incentive (PSI) Experience Tax Relief Tax Relief Short Term engaged in incentive
Acquisition (ITR) Government gas utilisation program
Program Relief Securities (Downstream (Upstream
(bonds issued Operations) operations)
by corporate
bodies and
supranational
also inclusive)
Tax holiday of
3 to 5 years,
Tax holiday of 3 to accelerated
Type of 5years, accelerated Tax capital Tax exemption,
Tax exemption1
benefit capital allowance, tax exemption allowance, tax Tax reduction.
free dividend. free dividend
and interest
deductibility.
Training
None
Benefit
There is a
Claimed in
statutory
the
Only Can only be requirement
assessment
claimable in utilised in Exception is for Within every
period in
How to Within the pioneer the third year the first tax for a 10 companies fiscal year of
which
Claim/ period. of year in year period engaged in filing tax
infrastructure
Timefra employment which from 2 gas utilisation returns.
or facility is
me of the new employees January to obtain
provided,
employees were first 2012. Ministerial
over 2
retained. employed. approval to
assessment
claim interest
periods.
deductions.
Federal Ministry of
Industry Trade and
Investment (FMITI)
is currently At least
reviewing the 60% of
scope and those To qualify for
implementation of employees the
pioneer status must be exemption,
incentive individuals the
administration and without prior infrastructure Interest on
Investment
the enabling laws work facilities must federal Grant of tax required to
in Nigeria Relief cannot experience be completed government holiday is separate crude
be carried and and be in use bonds subject to oil and gas from
Also, the Nigerian forward to employed by both the enjoys confirmation
Good to the reservoir
Investment other tax within 3 Company and indefinite that company
Know into usable
Promotion years. years of the public. exemption is engaged in products is also
Commission graduating Any unutilised from CIT & gas utilisation. considered as
collects a from portion can Capital
part of oil field
processing fee of schools or be utilised Gains Tax.
development.
2% of projected vocation. within 2
profits and existing Relief subsequent
companies cannot be assessment
applying for PSI carried periods.
are required to forward to
have additional another tax
investment up to year.
200% of
company's original
investment.
1These reliefs will expire on 26 April 2017, unless extended by the Nigerian Government. Qualifying companies with financial year-ends of
between 1 January and 26 April 2017, will be entitled to claim the reliefs in full in the corresponding tax year; while companies with
financial year-ends of between 27 April and 31 December will claim prorated reliefs to reflect the basis period up to 26 April 2017.

Nigeria (cont.)
Tax incentives (Table 2)
Free Trade Zones Export Credit Agro-Allied Industry Deep Offshore Mining of Solid
(FTZ) System and Inland Basin Minerals
Production
Sharing Contracts
Fiscal Incentives
Current minimum
value of annual
In practice, the export turnover is
minimum N5 million.
Minimum investment varies
Investment from one FTZ to This is subject to None
required another depending review from time
on the approved to time by the
activities. Nigerian Export
Promotion
Council (NEPC).
• Tax holiday of 3
years renewable
for 2 years.
• Exemption from • Exemption from • Investment Tax
all federal, state • Exemption from
payment of Credit (ITC) at
and local customs and
minimum tax. 50% of
government import duties in
Qualifying Capital
taxes, levies and respect of plant,
• Lower income Expenditure
rates. machinery
tax rate of 20 (QCE) for
equipment and
• Approved percent where Production
accessories
enterprises to the total gross Sharing
imported
import free of all sales (turnover) Contracts (PSC)
exclusively for
duties any capital is below ₦1 signed pre- July
mining
and consumer million. 1998.
operations.
goods, raw Tax credit for • Royalty rate of (However, the
Maximum • Agro-allied plant
materials, qualifying export 10% for plant and
benefit available and equipment
components, or companies. companies equipment can
articles to be enjoy only be disposed
operating in the
used in respect accelerated of locally upon
Inland Basin and
of any approved capital payment of the
graduated
activity within allowances. applicable customs
royalties rate for
the zone. and import duties).
companies in
• No restriction • Accelerated
• Repatriation of Deep Offshore
on the capital capital allowance
foreign capital operations
allowance on mining
investment and (ranging from 0%
claimable. expenditure
100% foreign to 12%
ownership depending on (95% initial
allowable. water depth). allowance and
retention of 5%
until asset is
disposed).

Nigeria (cont.)
Tax incentives (Table 2 – continued)
Free Trade Zones (FTZ) Export Credit Agro-Allied Deep Offshore and Mining of Solid
System Industry Inland Basin Minerals
Production Sharing
Contracts Fiscal
Incentives
• No import and export • Actual amount

license required and incurred out of
remittance of profits and reserves made for
dividends earned by environmental
foreign investors in the protection, mine
Maximum export free zone rehabilitation,
benefit allowable. reclamation and
available mine closure shall
(cont.) be tax deductible,
subject to
certification by an
independent
qualified person.
Tax exemption Tax Credit1 (against Lower income tax Tax credit Grant
future duty rate for total
payments) gross sales
Type of (turnover) below
benefit ₦1 million /
Minimum tax
exemption
Training
None
Benefit
Entire period of operating Applications must Within every Within every fiscal Only claimable in the
within the export free be submitted to the fiscal year of year of filing tax first three (3) years
How to zone. authority, along with filing tax returns. returns. of operations.
claim / evidence of full
Timeframe repatriation of export
proceeds.
• The 2 major legislation In practice, Tax exemption Petroleum A company may also
that regulate FTZ in qualifying exporters of the interest Investment be entitled to claim
Nigeria are; Nigeria must have fully earned by Banks Allowance (PIA) at an additional rural
Export Processing repatriated all from agricultural 50% of QCE for investment
Zone Act (NEPZA) and proceeds within 180 loans subject to PSCC’s signed allowance on its
Good to Oil & Gas Export Free days from the day of certain after July 1998. infrastructure cost,
Know Zone Act (OGEFZA). export. conditions. depending on the
• Rent-free land at location of the
construction stage, company and the
thereafter rent shall be type of infrastructure
determined by provided.
authority.
1These reliefs will expire on 26 April 2017, unless extended by the Nigerian Government. Qualifying companies with financial year-ends of
between 1 January and 26 April 2017, will be entitled to claim the reliefs in full in the corresponding tax year; while companies with
financial year-ends of between 27 April and 31 December will claim prorated reliefs to reflect the basis period up to 26 April 2017.

Sierra Leone
Additional incentives can be given if applied for by investors, however any agreement granting tax breaks and
incentives to a taxpayer is required to be ratified by the Parliament in order to have the force of law.
Tax Incentives
Investment and
Research and Development expenses Refinery Infrastructure
employment incentive
“Income derived from
any undertaking under
A minimum investment the Public-Private
For the purposes of income tax, any of $20,000,000 into a "Registered Businesses in SL
Partnership
expenses incurred on research and petroleum refinery that are at 20% Sierra
Infrastructure Projects
development by an investor, shall be project and employing Leonean owned are entitled
Minimum in excess of $20
eligible for deduction from profits of 100% at least fifty Sierra to corporate tax exemption if
Investment Million shall enjoy a
of the cost incurred up to the extent of the Leonean citizens shall over a given period, they
required corporate tax relief for
profit of the same year the expenditure is be eligible for the have certain amount of local
fifteen years. the
made but any unclaimed amount shall not following relief. employees and invest
importation of plants,
be available for future deductions. specified amounts of funds."
equipment and other
inputs, shall be duty-
free. "
Maximum None None
Up to 100% of the cost incurred is tax None
Benefit
deductible in the same year
available
Type of Tax Relief and

Tax Deduction Tax Exemption Tax Relief
benefit Exemption
In terms of income tax, Cost incurred up to

Expenses on training of local staff in expenses on training of local 100% of training local
approved training programmes, shall be staff in an approved training staff is tax free in the
eligible for deduction from profits of 100% programmes shall be eligible same year. for the
Training of the cost incurred up to the extent of None for deduction from profits of purpose of Income Tax
Benefit profits of the same year the expenditure is 100% of the cost incurred up
made, however, unclaimed amounts shall to the extent of profits of the
not be available for future deduction. same year the expenditure is
made.
Good to
Such a provision may be revised in subsequent Finance Acts, but will remain in force till repealed or amended.
know
Tax Incentives
Donation into Skills Development Fund Employment of Women
For the purposes of income tax, any investor who

For the purpose of the income tax any employer who
makes a donation into the Skills Development Fund,
employ a female personnel in managerial role or
Minimum Investment shall be eligible for 100% deduction of the donation
management position will be eligible for a tax credit of
required from profits for the same year that the donation is
6.5% of PAYE of that employee from the period 1
made, but any unclaimed amount shall not be
January 2016 to 31 December 2018.
available for future deductions.
Maximum Benefit Up to 100% of the cost incurred is tax deductible in 6.5% tax credit of the PAYE of the employee will be
available the same year allowed for the employer.
Type of benefit Tax Deduction Tax Relief
A tax deduction is applicable. This is an allowable tax deduction for the employer.
Training Benefit
Good to know Such a provision may be revised in subsequent Finance Acts, but will remain in force till repealed or amended.

Contact details
Dermot Gaffney
Associate Director
KPMG in South Africa
T: +27 82 686 9345
E: dermot.gaffney@kpmg.co.za
kpmg.com
kpmg.com/internationaltax
kpmg.com/app
The information contained herein is of a general nature and is not intended to

address the circumstances of any particular individual or entity. Although we
endeavour to provide accurate and timely information, there can be no
guarantee that such information is accurate as of the date it is received or that it
will continue to be accurate in the future. No one should act on such information
without appropriate professional advice after a thorough examination of the
particular situation.
© 2017 KPMG International Cooperative ("KPMG International"), a Swiss entity.
Member firms of the KPMG network of independent firms are affiliated with
KPMG International. KPMG International provides no services to clients. No
member firm has any authority to obligate or bind KPMG International or any
other member firm vis-à-vis third parties, nor does KPMG International have any
such authority to obligate or bind any member firm. All rights reserved.
The KPMG name and logo are registered trademarks or trademarks of KPMG
International.
Designed by KPMG South Africa
Publication name: Incentives in Africa

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Investing in

Central Africa Western Africa

Investing in Africa – A Guide to Tax / Incentives in Africa 2

Global trend towards regionalism

A shift towards diversification

Investing in Africa – A Guide to Tax / Incentives in Africa 3

• Foreign investments - Investments with a total Profits which were None

Training Benefit None

Investing in Africa – A Guide to Tax / Incentives in Africa 5

Investing in Africa – A Guide to Tax / Incentives in Africa 6

Tax reduction, Tax

The Company has to

Investing in Africa – A Guide to Tax / Incentives in Africa 7

Investing in Africa – A Guide to Tax / Incentives in Africa 8

MZN MZN Annual turnover MZN MZN MZN MZN MZN

• Accelerated • CIT Exemption of • CIT • Accelerated • Accelerated • CIT • CIT

Investing in Africa – A Guide to Tax / Incentives in Africa 9

Investing in Africa – A Guide to Tax / Incentives in Africa 10

Type of benefit Tax exemption Tax deduction

75% refund of expenditure incurred An additional deduction of 25%

Investing in Africa – A Guide to Tax / Incentives in Africa 11

None, but need to be

From 1 October 2012, The incentive is

Investing in Africa – A Guide to Tax / Incentives in Africa 12

Investing in Africa – A Guide to Tax / Incentives in Africa 13

Investing in Africa – A Guide to Tax / Incentives in Africa 14

On importation Written application to

Investing in Africa – A Guide to Tax / Incentives in Africa 15

Special Economic Zones

Type of benefit Tax reduction

Investing in Africa – A Guide to Tax / Incentives in Africa 16

None, but needs to conduct

Company which exports

Type of benefit Tax exemptions, Tax

Training Benefit None

Investing in Africa – A Guide to Tax / Incentives in Africa 17

• Reduced Corporate Income

Training Benefit None

• Losses are carried forward for

Investing in Africa – A Guide to Tax / Incentives in Africa 19

Investing in Africa – A Guide to Tax / Incentives in Africa 20

10 year corporate tax

Investing in Africa – A Guide to Tax / Incentives in Africa 21

Investing in Africa – A Guide to Tax / Incentives in Africa 22

Investing in Africa – A Guide to Tax / Incentives in Africa 23

Tax Incentives (Table 1)

Investing in Africa – A Guide to Tax / Incentives in Africa 24

Type of benefit Tax Deduction Tax Holiday

Training Benefit Not applicable

Investing in Africa – A Guide to Tax / Incentives in Africa 25

Special Economic Zones

Reduced Corporate Income Tax

Training Benefit Not applicable

Investing in Africa – A Guide to Tax / Incentives in Africa 26

Investing in Africa – A Guide to Tax / Incentives in Africa 27

Agriculture and agribusiness Quarrying and mining Priority areas

Capital allowances, deductions in

No cash grants provided by the Government of South Sudan*

Investing in Africa – A Guide to Tax / Incentives in Africa 28

Type of benefit Tax exemptions Tax reduction Tax reduction

Only holders of licences granted by

Investing in Africa – A Guide to Tax / Incentives in Africa 29

Investing in Africa – A Guide to Tax / Incentives in Africa 30