As we step into 2026, the global tax landscape continues to evolve rapidly in response to shifting economic realities, digital transformation, and coordinated international policy commitments. For businesses operating across borders, particularly in and with exposure to African markets, the coming year promises both fresh tax compliance obligations and strategic opportunities.
In 2025, tax authorities worldwide intensified enforcement, expanded data collection and reporting requirements, and solidified frameworks for digital and cross-border taxation. These trends are set to gain further traction and sophistication in 2026, with implications for corporate structures, global mobility, transfer pricing documentation, tax risk management and indirect tax regimes.
Below, we outline key developments and emerging areas of focus that businesses should be monitoring as part of their tax planning and compliance strategies in the year ahead.
Continued Implementation of Global Minimum Tax and BEPS Reforms
One of the most consequential international tax implementations now rolling out across jurisdictions is the global minimum tax framework, an outcome of the OECD/G20 Inclusive Framework under Pillar Two. This initiative aims to ensure multinational enterprises pay a minimum effective tax rate of 15% in each jurisdiction where they operate, thereby curbing profit shifting to low-tax jurisdictions.
Although the foundational rules have been in development for several years, 2026 is likely to see broader legislative adoption and enforcement of these measures. South Africa, for example, is advancing its global minimum tax legislation, with tax collections expected to reflect this integration from 2026 onwards.
For multinationals, this means recalibrating effective tax rate models, reassessing the attractiveness of tax incentive structures and analysing jurisdiction-by-jurisdiction tax impacts with greater precision.
Digital Economy Taxation and VAT Innovation
Digital economy taxation will remain a priority for both developed and emerging markets. Governments are increasingly seeking to capture tax revenue from cross-border digital services and e-commerce activities.
In Africa, countries such as Namibia have introduced VAT on imported digital services, aligning with the global trend of more aggressively taxing digital platforms and services.
Globally, jurisdictions like South Africa have reformed VAT rules applicable to digital services, with updated exemptions and compliance requirements for foreign suppliers providing services to local businesses.
In 2026, businesses should prepare for tighter VAT compliance environments, including electronic invoicing initiatives, digital filing and real-time reporting, all designed to improve transparency and reduce compliance leakage.
Transfer Pricing: From Documentation to Dispute Prevention
Transfer pricing continues to dominate as a strategic tax risk frontier. In 2025, several jurisdictions introduced more rigorous documentation requirements, expanded enforcement activity and heightened scrutiny on intercompany pricing arrangements, particularly in sectors like pharmaceuticals and regulated markets.
Looking ahead, businesses with cross-border value chains will need to strengthen documentation standards, adopt defensible economic analyses, and embed robust governance mechanisms to withstand audit pressure.
For African operations or multinational groups with African exposure, this means aligning transfer pricing policies with OECD best practices and ensuring contemporaneous documentation that can be readily defended in audits.
Residency, Substance and Exchange Control Intersections
Residency and substance continue to be key determinants of tax outcomes. While tax residency rules differ by jurisdiction, there is a clear trend toward tightening definitions and evidence requirements to establish where meaningful economic activity and decision-making occur.
In African jurisdictions, this trend intersects with exchange control tightening and reporting obligations. For instance, South Africa’s 2025 developments tying tax compliance status to offshore remittances underscore the integration between tax and exchange control regimes, a dynamic expected to persist into 2026.
Planning across borders now requires a holistic view of residency, substance, exchange control, and tax compliance, with clear evidence trails that link commercial reality to legal outcomes.
African Tax Policy Innovation and Regional Harmonisation
Across the African continent, tax policy is being recalibrated to modernise compliance, broaden the tax base and capture previously under-taxed economic activity, particularly in the digital and informal sectors.
Numerous countries are revising VAT systems, strengthening digital reporting, and modernising tax structures to support revenue mobilisation while remaining competitive for investment. Ghana’s repeal of controversial levies and other reforms illustrate how tax policy continues to be shaped by economic and social priorities. The Africa Tax Review
Moreover, bodies like the African Tax Administration Forum (ATAF) are advancing new model tax treaties that better protect local tax bases and reflect African policy concerns in bilateral tax negotiations. The Africa Tax Review
In 2026, regional harmonisation efforts, from VAT to tax treaty models are expected to gain momentum, requiring multinational companies to monitor changes across multiple jurisdictions.
Indirect Tax Reform and Compliance Modernisation
The indirect tax landscape in 2026 will feature continued digital transformation and administrative enhancements. Electronic invoicing, automated data submissions and integrated risk systems are becoming standard features in many jurisdictions.
These shifts are not merely technical; they reshape compliance obligations and can materially impact operating models and pricing strategies. As tax administrations invest in digital infrastructure, businesses should prioritise adaptive compliance systems that can integrate with evolving reporting frameworks.
Preparing for 2026: Practical Steps for Businesses
With these trends in mind, the following preparatory actions are recommended for businesses with international operations:
- Review tax governance frameworks: ensure robust, evidence-based documentation across transfer pricing, residency, and digital tax obligations.
- Update compliance systems: invest in digital tools and workflows that support e-invoicing, real-time reporting and multi-jurisdictional compliance.
- Revisit effective tax rate planning: reassess projections under global minimum tax rules and consider implications on investment planning.
- Monitor regional harmonisation initiatives: align planning with emerging tax treaty models and regional compliance standards.
- Strengthen cross-functional coordination: tax, legal, finance and operations teams should collaborate closely to identify and mitigate emerging tax risks.
Final Thoughts
The 2026 global and African tax outlook is one of increased transparency, advanced compliance systems and coordinated international standards. While this environment presents challenges, particularly in resource commitment and compliance complexity, it also offers opportunities for clearer planning, defensible governance and more sustainable cross-border operations.
Businesses that anticipate change, align their tax strategies with evolving policy directions, and invest in adaptive compliance infrastructure will be best positioned to thrive in this dynamic tax landscape.
As these reforms unfold, Regan van Rooy remains committed to helping clients understand the implications and navigate tax challenges with confidence. Get in touch with our team and enter 2026 on solid ground.
English 
French