Briefly Tax Law Report | September 2026

As of September 1, 2026, importers in Kenya are subject to more stringent documentation requirements under the Finance Act, 2026. The introduction of Section 23B to the Tax Procedures Act mandates that importers obtain and retain official export documentation from the country of origin for a period of five years.

This requirement, which was not included in the original Finance Bill, grants the Kenya Revenue Authority (KRA) enhanced oversight capabilities. By requiring documentation beyond the standard commercial invoice, the KRA has established a powerful new mechanism to verify the declared value of imports and challenge customs positions.

The Kenya Revenue Authority (KRA) has issued operational guidance regarding the VAT changes introduced by the Finance Act, 2026. Businesses are advised to prioritize updating their invoicing systems and tax classifications to ensure compliance with the new regulatory environment.

The updated framework brings fintech companies into the VAT net while providing long-awaited relief for staffing firms. Furthermore, the guidance clarifies that businesses selling on credit must now wait an additional year before they are eligible to recover VAT on bad debts, necessitating adjustments to internal accounting and cash flow projections.

The Kenya Revenue Authority (KRA) has announced a waiver of penalties and interest resulting from iTax system outages that occurred in September 2026. The disruptions, which impacted filing and payment processes shortly before the September 20 deadline, have necessitated this administrative relief.

Authorized under Section 89(5A) of the Tax Procedures Act, the waiver applies exclusively to instances of verified downtime. Affected taxpayers are encouraged to audit their tax ledgers and maintain comprehensive evidence of the disruptions to ensure they qualify for the relief provided by the KRA.

Starting 1 October 2026, Kenyan content creators on YouTube will be subject to a 5% withholding tax on their earnings, collected at the source by Google. While this tax obligation stems from the Finance Act, 2023, the shift marks a change in administrative practice, with Google aligning its collection process with that of Meta.

For creators, the immediate priority is ensuring their Kenya Revenue Authority (KRA) PIN is verified within the platform by the October deadline. Beyond the administrative requirement, this development signifies a broader integration of digital income into the national tax net, rendering creator earnings fully visible to the KRA.

The Kenyan Court of Appeal has reinforced strict adherence to statutory timelines in tax disputes, ruling on 16 September 2026 that the Kenya Revenue Authority (KRA) cannot unilaterally suspend objection deadlines while awaiting the outcome of separate litigation. Under this precedent, any tax objection not resolved by the KRA within 60 days is deemed allowed by operation of law.

These developments, coupled with a recent High Court decision raising the evidentiary burden for taxpayers, signal a more rigid environment for tax litigation. Taxpayers are now encouraged to maintain disciplined, timely filing practices, as the courts increasingly prioritize procedural compliance alongside substantive legal arguments.

Under the 2025 Tax Acts, non-resident companies generating income within Nigeria are now mandated to register for a Tax Identification Number, even in the absence of a physical local office. To enforce this compliance, the legislation imposes a ₦5 million penalty on any Nigerian entity that enters into a contract with a foreign vendor failing to provide proof of such registration.

This new requirement has created significant regulatory uncertainty, as noted by KPMG. A direct contradiction exists between the registration mandate and existing provisions that classify withholding tax as the final Nigerian tax liability for non-residents. This ambiguity leaves foreign businesses and their local partners in a precarious position regarding their statutory obligations.

Effective January 1, the Nigeria Revenue Service has implemented a stricter enforcement regime for late annual tax filings, increasing the penalty for non-compliance to ₦100,000. This represents a fourfold increase from the previous ₦25,000 fine, reflecting a broader effort under the consolidated Nigeria Tax Act to curb widespread corporate non-compliance across the country.

Beyond the initial penalty, the law introduces a compounding monthly fee of ₦50,000 for every month that a filing remains outstanding. These escalating costs are designed to incentivize timely reporting, but they also pose a substantial financial risk to businesses that fail to manage their regulatory deadlines effectively.

Nigeria’s tax landscape is currently undergoing a period of significant transition, marked by a 49% increase in first-half 2026 collections and the launch of the Nigeria Revenue Service’s new 'Inspiring Trust, Sustaining Growth' identity. Amidst these developments, the nation’s first Tax Ombud has issued a cautionary note, advising against a 'revenue-first' strategy that could undermine long-term tax reform goals.

Operational changes are also underway, with the Finance Ministry shifting from a flat late-payment interest margin to a market-linked rate, effective October 1, 2026. Simultaneously, the Tax Appeal Tribunal has delivered a nuanced, partially-favourable ruling in a recent dispute, highlighting the evolving nature of judicial oversight in the current tax climate.

Recent data from the National Bureau of Statistics indicates that Pay-As-You-Earn (PAYE) tax revenue across Nigerian states has reached ₦5.15 trillion. For legal practitioners, this milestone underscores a growing landscape of both opportunity and complexity within the mining and investment sectors, as the government seeks to foster a more robust economic environment.

This fiscal growth is expected to drive increased demand for specialized legal services, including project finance, regulatory compliance, and dispute resolution. As the sector matures, businesses must navigate potential policy reforms and heightened competition, making expert legal counsel essential for ensuring compliance and protecting capital investments within a transparent regulatory framework.

The Tax Appeal Tribunal in Abuja has ordered the Cement Technology Institute of Nigeria (CTIN) to pay over ₦2.02 billion in Companies Income Tax and Tertiary Education Tax. The ruling followed the dismissal of the institute’s appeal against additional tax assessments issued by the Nigeria Revenue Service.

This decision reinforces the authority of the Tax Appeal Tribunal and serves as a reminder for corporate entities to maintain meticulous compliance with tax laws. The tribunal also directed the Nigeria Revenue Service to recompute the institute's liability regarding exemptions for Treasury Bills and Bonds, highlighting the importance of substantiating tax positions during disputes.

The Anambra State Internal Revenue Service has initiated formal enforcement actions against non-compliant taxpayers following the conclusion of the Voluntary Assets and Income Declaration Scheme (VAIDS) on September 5. The enforcement drive is focused on taxpayers who failed to regularize their liabilities during the amnesty period.

Authorities are specifically targeting individuals and businesses that ignored previous 'Best of Judgment' assessments or failed to address underpayments. This move signals a shift toward more aggressive collection efforts for those who did not take advantage of the state's voluntary compliance window.

The Federal Government of Nigeria has announced a transition to a market-linked interest rate regime for late tax payments, which is scheduled to take effect on October 1, 2026. Under the new policy, interest on Naira-denominated tax payments will be calculated based on the Central Bank of Nigeria’s Monetary Policy Rate plus one percentage point.

To ensure the rate remains aligned with market conditions, the government has established a floor for these calculations tied to 364-day Treasury Bills. This change is intended to modernize the penalty structure for tax arrears and ensure that interest rates reflect current economic realities.

The 2026 Trust Filing Season, which opened on 19 September 2026 and runs until 22 January 2027, marks a significant shift in enforcement for the South African Revenue Service (SARS). For the first time, the tax authority is applying formal administrative penalties to non-compliant trusts, signaling a stricter approach to oversight in this sector.

Beyond the enforcement of filing deadlines, the regulatory landscape for trusts has evolved through specific legislative changes. These include new rules regarding the attribution of income when a donor emigrates, as well as a specific provision taxing the vested income of non-resident beneficiaries directly within the trust structure. Trustees must ensure their compliance frameworks account for these technical adjustments to avoid the newly implemented penalties.

The public comment period for the 2026 draft tax bills concluded on 28 August 2026, marking the end of the initial consultation phase for a wide range of proposed fiscal measures. These proposals encompass diverse areas of tax law, including adjustments to living annuity limits, regulations surrounding cross-border spousal donations, enhanced bank refund screening processes, and new relief measures for voluntary disclosures.

The draft legislation is now being prepared for tabling in Parliament. This process is expected to align with the timeline of the Medium-Term Budget Policy Statement, where the final versions of these bills will be presented for legislative approval. Stakeholders should monitor the parliamentary schedule closely as these proposals move toward enactment.

SARS has unveiled a comprehensive consultation paper outlining a new Digital VAT Model, representing the most significant overhaul of the country's value-added tax system since 1991. The proposed framework centers on the implementation of e-invoicing, a robust interoperability architecture, and a system for near real-time e-reporting. The initiative is designed as a multi-year project, with the authority targeting a phased, mandatory adoption schedule beginning in 2030.

This digital transformation is occurring alongside other critical developments in the VAT space. Current regulatory efforts also address the transition of schools out of the VAT system and the introduction of amended rules governing export zero-rating. These concurrent changes reflect a broader effort by the tax authority to modernize and tighten the administration of VAT across the economy.

International e-commerce platforms Shein and Temu are shifting their operational strategies in South Africa, moving away from direct cross-border imports toward local fulfillment and supply chain models. This pivot is a direct response to the South African Revenue Service's tightened customs regime on low-value imports, which has effectively curtailed the platforms' previous reliance on tax arbitrage.

According to the "Online Retail in South Africa 2026" report, produced by World Wide Worx in partnership with Mastercard, Peach Payments, and Ask Africa, the impact of these regulatory interventions has been more significant than initially projected. As a result of the increased regulatory pressure, Shein has reported a notable slowdown in growth, forcing a strategic transition toward establishing a physical footprint within the local market.

Estate duty planning remains a critical area of focus, with strategies often involving the donation of assets to a spouse to reduce overall tax liability and improve liquidity. These transfers currently benefit from Section 56(1)(b) of the Income Tax Act, while Section 4(q) allows for the postponement of estate duty when assets are left to a spouse upon death.

However, taxpayers should be aware of potential legislative shifts that could impact these arrangements. A proposed amendment is currently under consideration that may restrict these benefits exclusively to South African tax residents. Given these potential changes, individuals are encouraged to review their estate planning structures to ensure they remain aligned with evolving tax requirements.

The absence of a valid will in South Africa results in the distribution of assets according to statutory law rather than the deceased's personal intentions, a scenario that frequently leads to family disputes. Expert drafting is essential to ensure that an individual retains control over the inheritance process, including the timing and manner of asset distribution.

Beyond the immediate distribution of property, a well-structured will serves as a vital tool for managing tax exposure. Professional guidance is necessary to navigate the complexities of estate duty and capital gains tax, as the specific provisions within a will can significantly influence the ultimate tax burden on an estate.

A recent study commissioned by the Consumer Goods Council of South Africa highlights the severe economic impact of the illicit economy, which is estimated to cost the country R68 billion in annual tax revenue. Beyond the fiscal loss, the illicit trade is responsible for the displacement of over 87,000 jobs, underscoring the broader socio-economic consequences of smuggling and non-compliance.

In response to these challenges, SARS Commissioner Johnstone Makhubu has advocated for a significant investment in border-scanning infrastructure. The proposed R3.6 billion project aims to bolster the tax authority's ability to detect and intercept illicit goods, thereby strengthening border control and protecting the integrity of the national tax base.

SARS has provided clarification regarding the taxation of interest-free and low-interest employer loans, confirming that the official rate was reduced to 7.75% per annum effective 1 December 2025. This rate is determined by the Reserve Bank's repo rate plus a one-percentage-point margin, reflecting the current interest rate environment.

While the rate adjustment is straightforward, the application of the Seventh Schedule remains complex. Employers must ensure they correctly identify which loans qualify as taxable fringe benefits and which are eligible for specific exemptions. Because these rules are highly technical, they require a more precise interpretation than is typically provided in general summaries.

On September 3, 2026, the U.S. Treasury and the IRS introduced a proposed rule that could result in the revocation of 501(c)(3) tax-exempt status for private schools maintaining race-based policies. This regulatory development aims to align institutional tax benefits with federal anti-discrimination standards.

Private schools, donors, and parents are encouraged to review the full details of the proposal to understand the potential impact on their tax-exempt status. The guidance outlines the specific criteria for compliance and provides a timeline for the implementation of these new requirements.

New York’s FY 2027 budget implementation is currently underway, introducing significant shifts in the state’s tax landscape. Effective September 1, 2026, nicotine pouches are now subject to taxation consistent with other tobacco products. Additionally, the state has introduced tax relief for tipped workers, who are exempt from state income tax on up to $25,000 of tip income for the 2026 tax year.

Beyond these specific levies, the state and New York City have enacted targeted departures from federal tax law. These adjustments, which include certain retroactive provisions, represent a strategic shift in how the jurisdiction aligns with federal standards, requiring taxpayers to carefully review their compliance obligations for the current fiscal cycle.

California has undergone a comprehensive restructuring of its tax framework during the current legislative session. A newly enacted federal conformity statute now applies retroactively to the 2025 tax year, significantly altering the state's alignment with federal tax codes.

The legislative package also includes a partial exemption for the film industry from statewide business credit caps and establishes a novel incentive program for post-production activities. Looking ahead, the tax landscape remains fluid as voters prepare to decide on a proposed one-time wealth tax in the upcoming November 3, 2026, election.

Florida voters will decide the fate of a major property tax overhaul on November 3, 2026, via Amendment 3. If approved, the measure would increase the homestead exemption for non-school levies to $250,000 within a two-year period and implement a stricter residency requirement effective at the end of 2026.

The proposal also seeks to halve the growth cap on non-homestead assessments. Given that state economists estimate the recurring cost of these changes at approximately $12 billion annually, the amendment represents a significant fiscal shift that could substantially impact both local government revenues and individual property tax burdens.

Texas has significantly increased its business personal property tax exemption for the 2026 tax year, raising the threshold from $2,500 to $125,000 per location. This adjustment effectively eliminates the tax burden on equipment and inventory for many small businesses, with no formal application required to access the relief.

This move aligns Texas with a broader regional trend, as states including Arizona, Indiana, and Wyoming have also implemented increases to their respective business personal property exemptions this year. The policy change is expected to reduce administrative and financial overhead for a wide range of commercial entities operating within the state.

European energy markets are facing severe pressure as diesel prices reach record highs, averaging 2.23 euros per liter. This surge, equivalent to $9.63 per gallon in the United States, has prompted widespread government intervention across the region.

To mitigate the impact of these soaring costs, European governments are deploying a variety of fiscal and regulatory tools. These measures include the implementation of fuel tax cuts, direct subsidies, and the easing of environmental regulations intended to stabilize energy supply and provide relief to consumers and businesses.

The Zambian government has introduced a temporary, targeted suspension of customs duty on wheat imports via Statutory Instrument No. 65 of 2026. This measure allows 26 specifically named companies to import up to 300,000 tonnes of wheat duty-free between 1 and 30 September 2026.

The policy aims to address a national wheat deficit exceeding 350,000 tonnes and stabilize domestic bread prices. The Zambia Revenue Authority has clarified that this relief is strictly limited to the designated entities, and all other importers remain liable for full customs duties as the window closes on 30 September.

The Ministry of Finance and National Planning has initiated public consultations on the 2027–2031 Medium-Term Revenue Strategy, signaling a shift toward enhancing tax compliance rather than increasing tax rates. The government has explicitly committed to avoiding new taxes or rate hikes during this period.

This strategy is driven by data suggesting that nearly half of Zambia's potential revenue remains uncollected. By broadening the tax base and improving administrative efficiency, the government estimates that closing these compliance gaps could generate an additional K34 billion annually, providing a more stable fiscal foundation for the next five years.

The Zambia Revenue Authority (ZRA) has launched the Extended Voluntary Disclosure Scheme (EVDS) with full government backing. This initiative is designed to encourage taxpayers to come forward and settle outstanding tax obligations.

By offering a 100% waiver on penalties, the scheme provides a significant incentive for non-compliant taxpayers to regularize their status. This move reflects a broader effort by the ZRA to foster a culture of voluntary compliance and improve overall revenue collection efficiency.

ZRA Commissioner General Dingani Banda has issued a formal call for landlords to declare rental income, highlighting persistent under-declaration within the real estate sector. A 2018 assessment revealed that only five percent of rented properties were registered for tax purposes, identifying the sector as a major source of tax leakage.

This directive signals a heightened risk of audits and enforcement actions for property owners. For legal practitioners, the move underscores the necessity of ensuring clients are fully compliant with rental income reporting requirements to avoid potential penalties as the authority intensifies its focus on broadening the tax base.

The Zambian government has launched the Extended Voluntary Disclosure Scheme (EVDS), a three-month tax amnesty program running from 17 September to 31 December 2026. The program is intended to improve national tax compliance by allowing taxpayers to rectify past omissions.

For practitioners, this period offers a critical window for clients to regularize their tax affairs and mitigate the risk of severe penalties, interest, or criminal prosecution. Despite the potential benefits, early reports indicate an uptake of only 1,042 taxpayers, suggesting a possible need for increased awareness regarding the program's advantages for the broader tax base.

The Zambia Revenue Authority (ZRA) confirmed the disbursement of K16 billion in Value Added Tax (VAT) refunds by mid-2026. This significant payout highlights the authority's ongoing efforts to manage liquidity for businesses within the tax system.

In conjunction with this announcement, Commissioner General Dingani Banda has reiterated the need for improved tax compliance, particularly among landlords. The ZRA continues to emphasize the importance of accurate income declaration as a core component of its strategy to maintain a balanced and effective national revenue framework.

The Zambia Revenue Authority (ZRA) recently convened an ethics engagement meeting in Nakonde District, Muchinga Province, to address the necessity of integrity in tax administration. Nakonde Station Manager David Mungela emphasized that collective responsibility among stakeholders is essential to maintaining the integrity of the tax system.

This initiative highlights a strategic focus on curbing tax evasion, corruption, and illicit financial flows within the region. For businesses and practitioners operating in Zambia, particularly those involved in cross-border trade, the move signals an expectation of heightened transparency and stricter adherence to tax regulations. Stakeholders should anticipate increased scrutiny as the ZRA intensifies its efforts to protect government revenue and ensure a fair competitive environment.

The Zambia Revenue Authority (ZRA) has implemented enhanced system controls regarding the issuance of Tax Clearance Certificates (TTCs). Corporate Communications Manager Oliver Nzala confirmed that these measures are designed to combat ongoing issues with tax evasion and illicit financial flows.

The adjustment follows observations that non-compliant taxpayers have been successfully obtaining TTCs, undermining the authority's regulatory oversight. By tightening these controls, the ZRA aims to ensure that only compliant entities receive certification, thereby strengthening the integrity of the tax administration process and reducing opportunities for financial misconduct.

The Parliament of Zimbabwe is considering a proposal to introduce a sugar tax, modeled after the National AIDS Council (NAC) levy, to generate and ring-fence domestic funding for public health. Committee chairperson Discent Collins Bajila argued that current allocations to the Ministry of Health and Child Care are insufficient to meet national commitments or the needs of health institutions.

The proposal seeks to address the financing gap for the prevention and treatment of non-communicable diseases and mental health conditions. By referencing the 2001 Abuja Declaration, which calls for 15 percent of national budgets to be allocated to health, proponents are advocating for a fundamental shift in how the country finances its healthcare infrastructure.

The Zimbabwe Revenue Authority (ZIMRA) is currently enforcing rigorous controls over the import and export of specific commercial goods. Traders are now required to secure special permits for restricted items, while the authority continues to confiscate materials deemed absolutely prohibited.

This enforcement strategy is intended to protect consumers from hazardous products, conserve foreign currency reserves, and prevent intellectual property theft. Businesses engaged in international trade should ensure full compliance with these licensing requirements to avoid delays, seizures, or potential legal repercussions at the border.

The government of Zimbabwe has announced a five-month moratorium on the regulation of e-hailing services, including platforms such as InDrive and Bolt. This interim period is intended to provide space for the development of a comprehensive regulatory framework.

During this time, the authorities plan to initiate tax registration processes with the Zimbabwe Revenue Authority (ZIMRA) for both e-hailing platforms and their operators. This development marks a significant step toward formalizing the sector and integrating these digital services into the national tax system.

The Zimbabwe Revenue Authority (ZIMRA) has taken formal action to compel the Borrowdale Brooke Homeowners Association to disclose detailed records regarding property ownership and tenant information. The authority legally required the estate to provide names, lease dates, and contact details for residents.

This enforcement action represents a significant escalation in the government's efforts to identify and tax undeclared rental income. The move serves as a critical warning to real estate investors and compliance professionals that the tax authority is actively targeting high-value residential areas to ensure tax obligations are met.

Zimbabwe has officially implemented a Domestic Minimum Top-up Tax (DMTT) for the 2026 fiscal year, establishing a 15% minimum tax floor for qualifying multinational groups. Under these new rules, multinational entities must pay additional tax in Zimbabwe if their effective tax rate on locally generated income falls below the 15% threshold.

This development aligns the country's tax framework with international standards aimed at ensuring that large corporations pay a fair share of tax in the jurisdictions where they operate. Multinational groups with operations in Zimbabwe should review their tax positions to ensure compliance with this new minimum requirement.

Following the enactment of the Finance Act No. 7 of 2025, the Zimbabwe Revenue Authority (ZIMRA) has integrated five new tax types and several revisions into its Tax and Revenue Management System (TaRMS). Public Notice 50 of 2026 confirms that these changes are now fully operational.

Affected taxpayers are advised to register for each applicable new tax type immediately. Furthermore, taxpayers who previously filed returns on paper are required to re-enter those returns into the TaRMS system to ensure they are correctly processed and to avoid being flagged for outstanding filings.