The Global Forum on Transparency and Exchange of Information for Tax Purposes has published its second-round peer review report on Tanzania, assessing the country's implementation of the international standard on exchange of information on request (EOIR). The report was approved by the Peer Review and Monitoring Group on 23 June 2026 and adopted by the Global Forum on 23 July 2026. Tanzania's overall rating is Largely Compliant, a finding that reflects genuine progress since the first-round Phase 1 report adopted in 2021, alongside a set of significant outstanding deficiencies that will require sustained legislative and supervisory effort.
Structure of the review
The second round examines both the legal and regulatory framework in force as of 13 May 2026 and the practical implementation of that framework. The review period for practice covers EOI requests received and sent between 1 April 2022 and 31 March 2025. Tanzania is assessed against ten elements grouped into three pillars: availability of information (Elements A.1 to A.3), access to information (B.1 to B.2) and exchange of information (C.1 to C.5).
The summary ratings are:
| Element | Rating |
|---|---|
| A.1 Ownership and identity information | Partially Compliant |
| A.2 Accounting information | Largely Compliant |
| A.3 Banking information | Largely Compliant |
| B.1 Competent authority access powers | Compliant |
| B.2 Notification and appeals | Compliant |
| C.1 EOIR instruments | Largely Compliant |
| C.2 Network of EOIR relationships | Compliant |
| C.3 Confidentiality | Compliant |
| C.4 Rights and safeguards | Compliant |
| C.5 Effective exchange in practice | Largely Compliant |
The weakest rating, Partially Compliant on Element A.1, reflects persistent deficiencies in the availability of beneficial ownership information and drives the most substantive recommendations in the report.
Country context
Tanzania consists of Tanzania Mainland and Zanzibar, each with its own legislative framework for non-union matters, including company law and certain aspects of anti-money laundering (AML) regulation. This dual structure runs throughout the report: assessments frequently distinguish between the two jurisdictions, and some recommendations are directed specifically at Zanzibar where its legal position lags Tanzania Mainland.
The country had a population of around 68.6 million in 2025, with an estimated income per capita of approximately EUR 1,217. Agriculture contributes more than a quarter of gross domestic product; banking sector assets stood at TZS 72 trillion (EUR 24 billion) as of September 2025, spread across 42 banking institutions. Tanzania has been a member of the Global Forum since 2015.
Union taxes, including income tax and customs duty, are administered jointly across both parts of Tanzania by the Tanzania Revenue Authority (TRA). The Zanzibar Revenue Authority (ZRA) administers non-union taxes for Zanzibar, including VAT. The Minister of Finance is the formal Competent Authority for EOI, with powers delegated to the Commissioner General of the TRA.
Element A.1: ownership and identity information (Partially Compliant)
This element generates the most detailed analysis and the largest set of recommendations. The report identifies five distinct problem areas.
Nominee shareholding. Nominee arrangements are not prohibited under either Tanzania Mainland's Companies Act 2023 or Zanzibar's Companies Act 2013. Neither act requires nominees to disclose their status to the company or to the Registrar. During the on-site visit, private sector representatives confirmed that some legal professionals offer nominee services. The beneficial ownership framework provides only partial mitigation: it can reveal the economic interest behind registered shareholding, but it does not plug the legal gap of undisclosed nominee arrangements. Tanzania is recommended to ensure that nominee arrangements are always known to companies or authorities, and that nominator identity is available.
Definition of beneficial owner. The AML Act for Tanzania Mainland and the Anti-Money Laundering and Proceeds of Crime Act (AMLPOCA) for Zanzibar were both amended in 2022 to introduce definitions broadly in line with the Global Forum standard, using a 5% ownership threshold and a cascade approach ending in a senior managing official backstop. However, neither the legislation nor the accompanying AML Regulations provide sufficient guidance on "control by means other than ownership." The standard encompasses family connections, financial links, contractual arrangements and similar routes to control; none of these are addressed in current guidance. Further, the definitions do not adequately address the "look-through" approach where partners in a partnership or parties to a trust are themselves legal persons or arrangements. Tanzania is recommended to clarify both points.
Currency of beneficial ownership information. The AML framework imposes no specified frequency for updating customer due diligence (CDD), including beneficial ownership data. Banks indicated having their own risk-based internal timelines, but these vary. The Capital Market and Securities Authority accepts a maximum three-year interval in practice; other supervisors have no established standard. With the centralised beneficial ownership registers still being populated, the AML framework remains the primary source of beneficial ownership information, making this gap material.
Bearer share warrants in Zanzibar. Zanzibar's Companies Act 2013 continues to permit public companies to issue bearer share warrants. There are ten public companies in Zanzibar. A 2023 amendment requires the Registrar's approval for any issuance or transfer, but no approvals have been sought, and it is not known how many warrants have historically been issued or what capital they represent. The amendment does not require identification of holders. Tanzania is recommended to ensure that holders of bearer share warrants are always identified.
Implementation and enforcement. The centralised beneficial ownership register for Tanzania Mainland, operated by the Business Registration and Licensing Agency (BRELA), has been operational since 2022 but has achieved a filing rate of only around 12% of registered entities, rising from 17,931 submissions in 2022-23 to 28,535 in 2024-25 against a register of over 230,000 companies. BRELA's main lever has been denial of ORS (Online Registration System) services to non-filers under its "No BO, No Services" programme, but BRELA does not yet have powers to conduct on-site inspections of company records. In Zanzibar, the Business and Property Registration Agency (BPRA) has not yet operationalised its central beneficial ownership register; the online portal remains under development. Enforcement across AML supervisors is uneven: the Bank of Tanzania has incorporated AML and beneficial ownership checks into its supervisory plans, but supervisors for lawyers, auditors and accountants are primarily focused on awareness-raising and have not yet imposed meaningful sanctions.
More than 70,000 companies registered with BRELA or BPRA do not appear in the TRA's tax database, and a significant proportion of registered companies are non-compliant with annual return obligations. Annual return filing rates with BRELA improved from 58% in 2022-23 to 69% in 2024-25, but approximately 70,000 companies still failed to file in 2024. The existence of this non-compliant tail poses risks to the availability of both legal and beneficial ownership information.
Element A.2: accounting information (Largely Compliant)
Accounting record obligations arise primarily from tax law, supplemented by company and trust legislation. The TRA maintains an active enforcement and supervisory apparatus.
Two specific recommendations are made. First, Zanzibar's Companies Act contains no retention requirements for accounting records when a company ceases to exist. Tanzania Mainland's Companies Act 2023 was amended to require liquidators to retain accounting records for at least ten years, but this change has not been replicated in Zanzibar, and Zanzibar's legal framework provides no clear answer as to who holds records after dissolution. Tanzania is recommended to address this gap. Second, although the Tanzania Mainland amendment is in place, Tanzania has not yet sufficiently demonstrated that liquidators are implementing it in practice. A monitoring recommendation applies to both jurisdictions.
The broader concern about the 70,000-plus companies absent from the tax database also affects this element: entities outside the tax net carry elevated risks for accounting record availability, particularly where they hold overseas assets.
Element A.3: banking information (Largely Compliant)
Banking information is available through AML-driven CDD requirements supervised by the Bank of Tanzania. Three recommendations attach to this element.
The same definitional gap on "control by means other than ownership" applies to the identification of beneficial owners of bank accounts, and the same recommendation on clarity applies. More specifically, the AML framework allows banks to apply simplified CDD for low-risk customers; under simplified CDD, verification of the customer's identity is required but there is no explicit requirement to identify the beneficial owners of customers that are legal persons or arrangements before establishing a business relationship. Tanzania is recommended to close this gap. The absence of a specified frequency for updating beneficial ownership information in the CDD context also attracts a distinct recommendation.
Elements B.1 and B.2: access to information (Compliant)
Tanzania's competent authority, acting through the TRA, has adequate statutory powers to obtain information from any person within its territorial jurisdiction for EOI purposes, overriding confidentiality obligations. The Tax Administration Act (TAA) at section 7 gives international agreements precedence over domestic law. Notification requirements and taxpayer rights of appeal are assessed as compatible with effective exchange of information. Both elements are rated Compliant with no recommendations.
Element C.1: EOI instruments (Largely Compliant)
Tanzania has 13 double taxation conventions (DTCs), of which 11 are in force. Five of these, concluded with Sweden, Finland, Italy, Norway and Zambia, restrict exchange of information to residents of the contracting states, which limits the information Tanzania can exchange under them and is not in line with the standard. Tanzania is recommended to bring these relationships into conformity.
Tanzania signed the Southern African Development Community's Agreement on Assistance in Tax Matters in August 2012, which would provide EOI relationships with 11 jurisdictions, 9 of which are not covered by any other instrument currently in force. The ratification and notification process has not been completed. The report notes that several other parties to the agreement have already completed the necessary steps at their end. A recommendation to ratify the agreement at the earliest opportunity is made.
A significant recent development is that Tanzania's request to accede to the Multilateral Convention on Mutual Administrative Assistance in Tax Matters was accepted by the Coordinating Body in May 2026, and Tanzania was formally invited to sign. This step, if completed, would substantially expand Tanzania's EOI network.
Element C.5: effective exchange in practice (Largely Compliant)
During the review period Tanzania received two EOI requests and sent four. The volume is low, which limits the extent to which the EOI infrastructure could be tested. Two problems are identified.
First, the contact details of Tanzania's Competent Authority on the Global Forum's secure database were incorrect for the last six months of the review period following a change in the responsible official. The two inbound requests had to be resent by the treaty partner as a result. In January 2026, Tanzania added a generic email address to the database that should remain valid regardless of personnel changes. Tanzania is nevertheless recommended to ensure treaty partners are always kept informed of current contact details.
Second, Tanzania had experienced delays in responding to requests before and during the early part of the review period. It has since increased resources, produced an updated EOI manual and organised training for EOI officers. Because the review period yielded only a small number of requests, these improvements could not be fully evaluated in practice. A recommendation to monitor the effectiveness of the EOI function at all times is made.
Positive developments since 2021
The report acknowledges meaningful progress. Tanzania Mainland enacted a consolidated Companies Act 2023 with higher sanctions for non-compliance and strengthened beneficial ownership obligations. Both Tanzania Mainland and Zanzibar introduced AML amendments in 2022 providing improved beneficial ownership definitions. A centralised beneficial ownership register is operational in Tanzania Mainland. In 2023, revised editions of the AML Act, the Companies Act, the Business Names Registration Act, the Trustees' Incorporation Act, the Income Tax Act and the Tax Administration Act were consolidated for Tanzania Mainland. Tanzania was removed from the Financial Action Task Force's list of jurisdictions under increased monitoring in 2025. BRELA increased annual return filing rates and imposed TZS 3.4 billion (EUR 1.13 million) in penalties on late-filing companies during the review period.
What practitioners should note
The report's practical significance is sharpest in three areas. First, the low filing rate for the beneficial ownership register (12%) means that, for the foreseeable future, treaty partners requesting beneficial ownership information on Tanzanian companies will often be dependent on AML-sourced CDD records held by banks and other obliged entities, the quality and currency of which is uneven. Second, the incomplete EOI network, particularly the five DTCs that restrict information exchange to residents and the unratified SADC agreement, creates gaps in Tanzania's ability to respond to requests from certain jurisdictions. Third, the Zanzibar-specific issues around bearer share warrants and the absence of a live beneficial ownership register mean that Zanzibar-registered entities present a higher information-availability risk than their mainland counterparts.
Tanzania is expected to submit a self-assessment report to the Peer Review and Monitoring Group under the enhanced monitoring procedure, addressing each recommendation in this review.
The full document covers additional detail on partnerships, trusts, wakfs, foreign companies, specific enforcement statistics and annexes listing all recommendations, Tanzania's EOI mechanisms, the review methodology and Tanzania's response to the review report. The source document is truncated in the extract above; the full report contains substantially more analytical content.