Tax Transparency in Sub-Saharan Africa: Evidence from the OECD 2025 Peer Review

This study provides a theory-driven comparative institutional analysis of Country-by-Country Reporting (CbCR) implementation across all Sub-Saharan African jurisdictions included in the OECD 2025 peer review. Using qualitative document analysis of the OECD (2025b) peer review reports, the study conducts a cross-jurisdictional comparative analysis of Sub-Saharan African jurisdictions, coding domestic legal frameworks, exchange-of-information mechanisms, and confidentiality and appropriate-use safeguards. The findings reveal substantial heterogeneity in CbCR implementation across Sub-Saharan Africa. While a limited number of jurisdictions achieve full compliance, many remain partially compliant or non-compliant, with recurrent deficiencies concentrated in domestic legal frameworks, exchange mechanisms, and data-protection arrangements. Illustrative cases indicate that definitional gaps, incomplete filing requirements, and weak confidentiality safeguards are the most frequent sources of adverse peer review recommendations. The results suggest that legal adoption alone is insufficient without complementary institutional capacity and credible administrative enforcement. The analysis identifies sequential institutional capacity constraints at the stages of legal transposition, exchange integration, and data governance that systematically explain partial compliance and non-compliance. The study underscores the importance of strengthening institutional capacity, sequencing legal and administrative reforms, and enhancing regional cooperation to improve CbCR implementation in developing economies. The analysis is limited to peer review narratives and therefore captures implementation architecture rather than firm-level behavioural responses or revenue effects. The study provides a systematic regional assessment of CbCR implementation in Sub-Saharan Africa by constructing a comparative dataset from the OECD’s 2025 Compilation of Peer Review Reports and linking observed implementation patterns to institutional and deterrence-based mechanisms. The findings offer practical guidance for tax administrations, auditors, and policymakers seeking to strengthen transfer-pricing oversight and information-exchange frameworks in developing economies.