Anahita Riegler

Over the years, Africa's share of global investment flows has been much lower compared to other world regions. The African Continental Free Trade Area (AfCFTA) seeks to remedy this through the Investment Protocol, which will include provisions aimed at addressing some of the non-tariff barriers (NTBs) to Africa's investment. As negotiations on the Protocol's provisions continue to take shape, a key area that has received little attention is preferential Rules of Origin (RoO). Most literature on RoO has focused on their impact on trade flows and failed to take note of their role in...

Rapid progressions in cross-border e-commerce has revolutionized international trade and made it possible for businesses to transact in a borderless Internet environment. However, most international tax treaties still apply source-based taxation principles, including the permanent establishment concept, in taxing income derived from international commerce. This article examines whether source-based taxation remains theoretically valid in the territorial taxation of cross-border e-commerce income. It analyses the application of the permanent establishment concept to e-commerce corporate income and reviews some of the existing challenges and the current responses to these challenges at the academic and international level.