addressed in the EGM thematic area under Question 5, which asks: ―What measures has your country taken to increase domestic resource mobilisation including public and private savings and capital formation, and to reduce capital flight?‖ In the event, relatively little is said in the CRRs about resource mobilisation from the continent‘s natural resources. What is put forward on this issue is contained in three of the CRRs, these being Tanzania, Sierra Leone and Zambia, while the Mozambique CRR touches on it as well. These raise perceptions that host countries are not benefiting from large investments (particularly in the extractive industries). Investors were benefiting from legal provisions that stacked advantages in their favour. Surprisingly, given the importance of this issue, the standards do not deal with it in any detail. The following have a bearing on it:     OAU, The New Partnership for Africa‘s Development (NEPAD) (2001) OAU, African Charter on Human and Peoples‘ Rights (1981, Nairobi, Kenya) OAU, Memorandum of Understanding, Conference on Security, Stability, Development and Co-operation in Africa (2002, Durban, South Africa) UN, World Summit on Sustainable Development, Johannesburg Declaration on Sustainable Development (2002, Johannesburg, South Africa) In Zambia, for example, it is stated that tax breaks are offered to new investors, but companies then close down and re-register, taking fresh advantage by double dipping.325 The CRR then concludes: ‗This tendency was perceived to permanently deprive the locals and the government of revenue for development.‘ 326 Similar findings appear in the Sierra Leone CRR, which notes the concessions offered to mining investors in the country, along with allegations of unethical conduct, such as operating front companies to avoid taxes.327 In Tanzania, generous tax incentives (especially in the period before 2010) have meant that companies have been able to avoid taxes by offsetting their capital expenditure against their tax liability, and allowing an indefinite loss carry forward, which created an incentive to declare losses and thereby avoid taxes.328 The Mozambique CRR deals with this in less detail, but makes a similar point – that tax incentives for large projects are depriving the country of revenue. The CRR recommends renegotiating the underlying contracts.329 The standards refer to the need for adequate resources to be martialled for the continent‘s development, and call for greater mobilisation. Concerns are expressed about capital flight. The role of natural resources in resource mobilisation is addressed obliquely. The African Charter on Human and Peoples‘ Rights advances a quasi-moral claim that people have a right to dispose of their wealth and natural resources as they see fit. The CSSDCA Memorandum of Understanding states that ‗Africa‘s strategic and natural resources are the property of the people of Africa and the leadership should exploit them for the common good of the people of the continent, having due regard for the need to restore, preserve and protect the environment.‘ However, very little guidance is provided as to how these resources should be converted into actual revenues. If one accepts that countries are failing to extract adequate benefit from their natural resources, the question arises as to why these arrangements have been allowed to persist. The Tanzania CRR provides an indication of this: ‗Mineral Development Agreements are generally regarded as skewed in favour of foreign companies. For instance, tax stability clauses in MDAs precluded the Government of Tanzania from raising tax or royalty rates.‘330 Agenda 2063 envisions a commodities strategy to ‗enable African countries to add value, extract higher rents from their commodities, integrate into Global Value Chains, and promote vertical and horizontal diversification anchored in value addition and local content development‘.323 Concerns have also been expressed about tax avoidance and tax evasion by large companies. These may be legal (such as structuring operations to take maximum advantage of tax loopholes, even where doing so violates the intention of the tax code), or illegal (such as false invoicing). Given the complexities of this manipulation and the sophistication of the companies perpetrating it, it requires a degree of forensic skill to detect and combat. These skills are in short supply in most African countries.331 The recent report into illicit A related issue is illicit financial flows, illegal movements of funds from one jurisdiction to another, avoiding the requisite obligations, such as taxes. An investigation into the matter carried out under the aegis of the AU and the United Nations Economic Commission on Africa (UNECA) estimated that the continent was losing around $50 billion annually, and had suffered a loss of $1 trillion over the preceding 50 years.324 325 326 327 323 324 328 Agenda 2063, p. 97. High Level Panel on Illicit Financial Flows from Africa, Illicit Financial Flows: Report of the High Level Panel on Illicit Financial Flows from Africa, 2015, p. 13. 329 330 331 60 Zambia CRR, pp. 81-82. Zambia CRR, p. 82. Sierra Leone CRR, p. 86. Tanzania CRR, p. 226. Mozambique CRR, pp. 175-176. Tanzania CRR, p. 226. Africa Progress Panel, Africa Progress Report 2013, Equity in extractives: stewarding Africa‟s natural resources for