Position: EXPERT ON DOUBLE TAXATION AGREEMENTS – Pretoria, South Africa
HISTORICAL FRAMEWORK OF THE MISSION
- Illicit Financial Flows (FFIs) in Africa represent a considerable setback to progress in mobilising the continent’s internal resources. According to the United Nations Economic Commission for Africa, the continent annually loses about 50 billion US dollars due to FFI. These flows very often stem from tax evasion, incorrect invoicing of trade, gaps in existing legal and contractual agreements, including but not limited to tax treaties. The magnitude and impact of IFFs underscores the need for robust policies and cooperation, both in Africa and around the world, to reduce these damaging flows.
- ATAF has taken proactive measures to combat IFFs by formulating a strategic approach focused on transparency, international cooperation and legislative and administrative reforms, on other key pillars needed to stop IFFs. In an attempt to improve this strategy, the ATAF, working in liaison with partners including the African Union Commission, identified the use of a standard treaty model in tax matters as a determining factor in ensuring that Member States negotiate their treaties, adopting a sufficient strategy to prevent the inclusion of loopholes that provide the FFI.
- The ATAF DTA Type Agreement has served and continues to serve ATAF members to ensure compliance with measures to combat Taxable Base Erosion and Profit Transfer (BEPS) and FFI for years. Ongoing global reforms, changes in the way and manner of doing business, and national and international changes in tax policy in support of mobilizing public resources for development have necessitated the redesign and revision of the ATAF.
- Recognising the mandate of the AU Specialised Technical Committee (STC) on Finance, Monetary Affairs, Economic Planning and Integration for ATAF and its partners to design tools to combat IFFs, and aware of the immense potential in the continent’s resource mobilisation sphere, to the ATAF discerns the urgency of channeling these resources appropriately for the well-being and development of African nations. Consolidating the foundations laid by the IFF mitigation framework, designed by the Joint Technical Committee (JTC), the ATAF identifies the compelling need for a comprehensive DTA model. This Model will serve as a reflection that helps members absorb an FFI-proof approach to treaty negotiation, such ascrystallising the prospects for collaboration and best practices from the point of view of developing countries into pragmatic measures.
Required profile for job ad : EXPERT IN DOUBLE TAXATION AGREEMENTS – Pretoria, South Africa
GENERAL SCOPE OF MISSION
In order to fulfil the mandate set out in this mission, the expert shall responsible for the following.
- Review and analysis:
- Study the strategy to combat ATAF FFI, observing how the ATAF DTA Type Agreement can help promote the fight against FFI;
- Conduct a critical review of the ATAF DTA Type Agreement, noting areas calling for updating in the light of emerging considerations and realities on the continent;
- To analyse existing national treaty policies and/or models in the ATAF Member States with a view to identifying gaps that can be addressed by adopting the ATAF Type Agreement;
- To study the recent events in the international tax spectrum, in particular focusing on tax treaties, including the updating of Article 5.°, on Permanent Establishment, of article 8.°, on International Maritime and Air Transport, of article 12.°- B, on the principle Subject to the Tax Rule (STTR) and Article XX, all with the aim of evaluating its relevance to the ATAF Type Agreement and inspiring the processes of formulation of the tax treaty policy in the continent;
- Work closely with the experts of the ATAF Secretariat, the Cross-Border Technical Committee and other stakeholders, in particular the ATAF Joint FFI Technical Committee, to obtain relevant guidance and expertise to ensure comprehensive and quality work is carried out.
- Preparation of the technical document:
- Reflect the recommended changes to the ATAF Standard Agreement on DTAs on the basis of stakeholder studies, analyses, reviews and opinions;
TANGIBLE RESULTS
- Initial draft of the DTA model, product of the review and consultations with stakeholders – April 2025
- Explanatory Memorandum – April 2025
- Subcommittee of the Specialised Technical Committee (STC) to receive its grants – May 2025
- DTA model finalized and validated – October 2025
MAIN REQUIREMENTS REQUIRED
The ideal candidate should possess the following qualifications and experience:
- Advanced degree in economics, taxation, law, finance, public administration or a related branch;
- At least 10 years of experience in the area of tax policy or administration, in particular in matters of tax treaties, their interpretation and administration;
- Demonstrated experience in FFI, especially in the African context;
- Prior experience in the field of drafting policy documents, reports or comparable documents;
- Strong analytical, research, communication and writing skills;
- Proven ability to interact and foster discussions among high-level stakeholders.
- Solid language skills in English.
Advantages of surplus value:
- Excellent project or stakeholder management skills;
- Ability to maintain confidentiality;
- Competence to communicate in Portuguese or French.
MISSION DURATION
The mission must start the 17 February and end on 30 April 2025. The number of feasible days within the mission is
Job criteria for job ad : EXPERT IN DOUBLE TAXATION AGREEMENTS – Pretoria, South Africa
- Job category : Accounting, controlling, finance
- Industries : Banking, insurance, finance
- Employment type : Fixed-term contract
- Region : Ashanti – Brong Ahafo – Central – Eastern – Greater Accra – Northern – Upper East – Upper West – Back – Western – International
- City : Pretoria, South Africa
- Remote work : No
- Experience level : 5 To 10 years – More than 10 years
- Educational level : Master
- Spoken : english > fluent – french > fluent – portuguese > good level
- Number of Position(s) : 1
- Team management : No
