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This is the third in ATAF’s series of Technical Notes on the tax challenges arising in Africa from the digitalisation of the economy. The second Technical Note CBT/TN/02/2019 titled “Inclusive Framework proposals to address the tax challenges arising in Africa from the digitalisation of the economy”1 provided an overview of the proposals set out in the Public Consultation Document titled “Addressing the Tax Challenges of the Digitalisation of the Economy” that might form part of a long-term global consensus-based solution to the broader tax challenges arising from the digitalisation of the economy and the remaining BEPS issues.