As we look back on 2025, one thing becomes clear. This was a year defined by movement. Courts shifted long held interpretations. Governments rewired tax systems. Regulators tightened rules that many assumed were settled. And across Africa, Europe and key global hubs, tax authorities signalled a common message. Expect closer scrutiny, clearer evidence, and stronger alignment with global standards.
At Regan van Rooy, we spent the year unpacking these developments across the jurisdictions where our clients operate. What emerged is a narrative of convergence. Transfer pricing rules became more assertive and documentation focused, residency rules sharpened, exchange control rules tightened, and corporate tax legislation grew more sophisticated and less tolerant of ambiguity.
Below is how the year unfolded when viewed through the bigger picture.
Transfer Pricing Takes a Front Row Seat in 2025
The year opened with a powerful reminder that transfer pricing is no longer a technical backroom issue but a headline risk. Ireland delivered one of the most discussed TP cases of the year, centred on whether stock-based awards should form part of a cost-plus arrangement. The Irish Tax Appeals Commission placed economic reality above accounting presentation, confirming that functional analysis and risk allocation prevail over pure reporting mechanics.
This theme resurfaced throughout the year. Mauritius, historically light touch on TP, introduced its first formal TP documentation rules through the Finance Act 2025. For the first time, multinationals will need structured local files, master files, benchmarking and defensible economic analysis. The country has effectively moved from principle to practice.
Taken together, these developments show a global trend. Tax authorities are becoming more aligned with OECD expectations and less tolerant of undocumented or informal pricing approaches. Functional accuracy, contemporaneous evidence and internal consistency across jurisdictions matter more than ever.
This trend is not unique to developed markets. In Kenya, the Beta Healthcare versus Kenya Revenue Authority dispute highlights how vigorously tax authorities are examining intercompany pricing in sectors like pharmaceuticals, where profitability and public interest intersect. The case emphasises the need for precise benchmarking and transparent documentation, especially in regulated industries.
Further south, the Zambia Revenue Authority secured a notable transfer pricing dispute win, offering lessons for taxpayers on documentation, functional analysis and the importance of contemporaneous evidence. These cases collectively underline that African tax authorities are not just signalling intent but are actively asserting TP positions with real consequences.
Residency, Substance and Corporate Presence Under the Microscope
2025 placed significant focus on residency rules, corporate presence and where control really sits.
We touched on the application of Central Management and Control test in Mauritius reminding groups that residency depends not on incorporation but on where strategic decisions are actually made. Boards must act independently, document deliberations and avoid rubber stamping shareholder directives.
At the individual level, South Africa’s rules on tax residency continued to catch the attention of expatriates. Many who assumed non residency status were reminded that SARS applies strict tests including ordinary residence, physical presence and treaty tiebreakers. Formal cessation remains essential for certainty.
Across jurisdictions, the message is consistent. Residency is not a paperwork exercise but an evidence-based one. Groups with cross border structures need to be able to demonstrate where decisions are made and where economic influence truly lies.
A Year of Big Legislative Moments
Several jurisdictions introduced structural reforms that reshaped planning considerations for businesses and investors.
Mauritius delivered a busy mid year cycle, beginning with a national budget focused on fiscal rebuilding. This included VAT threshold reductions, new minimum tax rules for multinationals, changes to excise duties and sharper administration tools.
The Finance Bill that followed deepened these changes and added further compliance rigour. Eligibility for the partial exemption regime on interest is now tied directly to licensed activity and substance, a notable shift that moved away from the Supreme Court’s earlier finding that interest income could qualify regardless of linkage to core business.
South Africa’s Draft TLAB represented one of the most technical corporate tax shifts of the year. Its IFRS based approach to hybrid equity instruments widened the scope of taxed dividends significantly before the proposals were scrapped, while cross border reorganisations, CFC rules and interest limitations all received targeted tightening.
In Nigeria, a landmark legislative overhaul redefined corporate residence, CFC rules, capital gains, VAT and more. This introduced a modernised framework with major consequences for inbound and outbound groups.
Zimbabwe’s 2026 Budget added another chapter to Africa’s reform story. The proposals represent a sweeping rewrite of the tax code, with corporate, individual and indirect tax bases all under revision. For investors and operating groups with exposure to southern Africa, the scale of these changes underscores how dynamic African tax landscapes have become and why localisation of planning is now essential.
Tax legislation in 2025 was not subtle. It leaned heavily toward transparency, economic substance and coordinated global standards.
Global Politics Meets Tax Policy
Few events illustrated the interconnectedness of geopolitics and tax planning like the resurgence of United States tariff policy. The sweeping increases in tariffs created volatility in global supply chains and raised questions about cost structures, pricing models and sourcing strategies. Markets reacted quickly, and cross border businesses had to pay close attention to knock on effects for customs, VAT and profitability.
Tax planning increasingly requires an understanding of broader economic forces, and 2025 provided a clear demonstration of this.
A Hard Stop on Outflows: Exchange Control Tightens in South Africa
Just as the year neared its close, South Africa delivered an unexpected regulatory twist. The South African Reserve Bank quietly introduced changes requiring that non residents receiving South African source income must show SARS tax compliance before funds can be remitted offshore. Banks are now required to verify a TCS AIT PIN or Manual Letter of Compliance before releasing payments ranging from dividends to rental income.
This new alignment of tax residency and exchange control processes signals a much stricter future. Structures with non-resident beneficiaries or shareholders will need to revisit their compliance positions early to avoid delays or blocked transfers.
The Bigger Picture Emerging from 2025
When woven together, the year’s developments form a clear narrative.
- Substance, evidence and documentation became the defining currency of cross border tax.
- Authorities coordinated more closely with global standards than ever before.
- Businesses operating across Africa, Europe and Mauritius faced rising administrative expectations, from transfer pricing files to residency proof to exchange control approvals.
- Tax law became more aligned with economic reality, not accounting form or historical practice.
For multinationals, investors, family offices and expanding African businesses, 2025 reinforced the importance of proactive planning, defensible structures and ready documentation.
Looking Ahead to 2026
If 2025 was the year of alignment and tightening, 2026 is likely to be the year of implementation and enforcement. New rules across Mauritius, South Africa, Nigeria and Ireland take effect within months, and authorities are signalling that they expect taxpayers to keep pace.
Our team will continue monitoring these developments and providing the practical guidance needed to navigate them.
For now, if you missed any of the deep dives that informed this review, you can explore the full list of insights here or get in touch if you’d like to discuss these further.
Here is to another year of clarity, good planning and confident decision making.
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