An In-Depth Look at International Tax in Africa: Part 1

GILTI Conscience

Conversations surrounding transfer pricing practices rarely span to include the myriad regulations throughout Africa. However, across the continent, there are vast distinctions between countries that are thriving under new international tax rules and others that are struggling to keep up.

Lolade Ososami, a partner and head of the tax team at Udo Udoma & Belo-Osagie, says that transfer pricing has grown and evolved in Africa over the last decade. When the OECD released the BEPS action plans in 2018, it had a huge impact on tax practitioners, particularly in Nigeria.

Zach Pouga, a partner in the International Tax Group at Ernst & Young, encounters transfer pricing in nearly every aspect of his work. He frequently deals with BEPS 2.0, Pillar One and Pillar Two when advising his clients regarding their presence in Africa, as well as helping governments across Africa understand the complexity of new tax rules.

In this episode of the GILTI Conscience podcast, Lolade and Zach join our hosts to dive into the evolving world of international tax throughout Africa. From how U.S. multinationals operating in Africa approach transfer pricing to how Africa-based companies and regional governments are branching out, Lolade and Zach explore the complexities of transfer pricing and international tax.

💡 Featured Guests 💡

Name: Lolade Ososami

What she does: Lolade heads the taxation and mining and metals teams at Udo Udoma & Belo-Osagi. Her years of experience as a commercial lawyer in Nigeria, the largest emerging market in Sub-Saharan Africa, has equipped her with a vast knowledge of the legal and regulatory framework for international investment in the region.

Organization: Udo Udoma & Belo-Osagie

Words of wisdom: “Success is relative. It depends on which side of the fence you're standing. You have all these audits, all this controversy. The taxpayer is spending a lot more money trying to resolve disputes. So is tax really being collected, even? I don't know if that looks like success.”

Connect: LinkedIn

Name: Zach Pouga

What he does: As a partner in the International Tax Group at Ernst & Young, Zach focuses on U.S. companies with a presence in Africa and Africa-based companies looking to expand to the U.S., often working in tandem with the African Union and regional governments.

Organization: Ernst & Young

Words of wisdom: “The thing I hear a lot is that the government doesn’t have the manpower to apply the rules they don’t understand, and the effectiveness of which they are not sure of. So it’s a very deliberate governmental decision to try to allocate resources to understand these complex policies that are coming out when they have no assurance of the effectiveness in actually raising funds for them.

Connect: LinkedIn

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GILTI Conscience is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. Skadden’s tax team is recognized globally for providing clients with creative and innovative solutions to their most pressing transactional, planning, and controversy challenges. The insights and views presented in GILTI Conscience are for general information purposes only and should not be taken as legal advice for any individual case or situation. The information presented is not a substitute for consulting with an attorney, nor does tuning into this podcast constitute an attorney-client relationship of any kind.