Titus, Afton2025-02-122025-02-1220252023-10*A2025http://hdl.handle.net/2263/100766Thesis (PhD (International Tax Law))--University of Pretoria, 2023.This study explores the creation of an African Continental Model Multilateral Tax Agreement (MMTA) to address the limitations of current bilateral tax treaties and enhance existing African Regional Economic Community (REC) frameworks for more effective taxation of cross-border business profits. Focusing on critical international taxation framework issues such as taxing rights allocation, Permanent Establishment criteria, and tax dispute resolution, it compares African REC MMTA provisions with those in non-African agreements to identify key weaknesses and propose improvements. The proposed MMTA aims to ensure equitable taxing rights, update nexus rules to capture both physical and digital businesses, and provide robust dispute resolution mechanisms to foster investment. It advocates for harmonized tax policies and tax agreements across African RECs to minimize tax competition, promote intra-African trade, and support regional economic integration under the African Continental Free Trade Area (AfCFTA). By aligning with the Abuja Treaty’s objectives, the framework seeks to enhance revenue mobilization and sustainable economic development in Africa. This research provides a roadmap for creating a tailored multilateral tax treaty that balances diverse regional interests, addressing Africa’s development financing needs while promoting cross-border taxation efficiency.en© 2023 University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria.UCTDSustainable Development Goals (SDGs)International taxation frameworksTax treatiesContinental model multilateral tax agreementAfrican Continental Free Trade Area (AfCFTA)Revenue mobilisation for developmentThesisu19388714https://doi.org/10.25403/UPresearchdata.28395305