As people, businesses, assets and financial transactions move increasingly across borders, tax administrations face a fundamental challenge: their powers and access to information often stop at the national border.
Yet tax risks do not.
For African countries seeking to combat tax evasion and avoidance, protect their tax bases and mobilise the domestic resources needed for development, cooperation between tax administrations is becoming increasingly important. This is where the ATAF Agreement on Mutual Assistance in Tax Matters (AMATM) plays a critical role.
The AMATM is an African-created, African-led international treaty that enables participating African tax administrations to assist one another in the administration and enforcement of their tax laws. It provides a legal framework for cooperation, including the exchange of relevant tax information, tax examinations abroad, simultaneous tax examinations, joint audits and assistance in the collection of tax debts.
In practical terms, the Agreement helps tax administrations look beyond their borders when investigating complex tax risks. It can enable them to access information from counterpart administrations, coordinate examinations and seek assistance in recovering taxes where cross-border activities, assets or taxpayers are involved.
This matters even more as economic activity across Africa continues to grow. Increased continental trade and the movement of people, capital and businesses create new opportunities for economic development—but also make cooperation between tax administrations essential. The AMATM is designed to provide an African framework through which countries can strengthen that cooperation, in line with international standards and best practice.
Turning Cooperation into Action
The benefits of the AMATM extend beyond information sharing. The Agreement covers assistance across several critical areas, including the exchange of information, tax examinations abroad, simultaneous examinations and assistance in the collection of taxes.
For tax administrations confronting taxpayers and businesses with operations, assets or information across multiple jurisdictions, these tools can strengthen investigations, improve audit capabilities and support more effective enforcement.
The Agreement is multilateral, meaning that by joining the AMATM, a country immediately obtains the ability to cooperate with all other parties, without having to separately negotiate individual agreements one at a time. In addition, because the Agreement is focussed only on administrative cooperation, it opens gateways for mutual assistance without bringing more challenging issues of allocation of taxing rights into the equation.
Importantly, the Agreement also provides safeguards around the use of information. Information exchanged under the AMATM must be treated as secret or confidential and used for authorised purposes under the Agreement and relevant domestic laws.
A Practical Roadmap for Joining the AMATM
Recognising that joining an international agreement can involve a number of domestic and legal procedures, ATAF has developed a comprehensive Toolkit for Joining the ATAF Agreement on Mutual Assistance in Tax Matters.
The Toolkit provides member countries with practical guidance on the process of joining the Agreement, setting out the key steps involved and providing adaptable templates to support countries through the process.
All ATAF member countries are entitled to become parties to the Agreement, and the Toolkit guides them from expressing their intention to join through domestic approval, signing, ratification and the designation of a competent authority.
The AMATM represents more than a legal instrument. It is a practical mechanism for African countries to work together against tax risks that no country can effectively address alone.
Through the Toolkit, as well as its extensive training and bespoke capacity building programmes on the effective use of international cooperation mechanisms in tax matters, ATAF is helping turn that cooperation from an ambition into action—supporting member countries to join the Agreement and strengthen Africa’s collective capacity to combat tax evasion and avoidance, protect domestic revenues and build stronger, fairer tax systems.
