I served as an editor in the student issued popular education publication Pathways to Free Education. From 2016, I co-coordinated a knowledge generation project based on written submissions from scholars, activists, facilitated workshops with workers, students, community organisations, interviews with trade union members, and any other interested members of the public. The collective also hosted a number of summer and winter school sessions. This work culminated in co-published material spanning four volumes of pamphlets, booklets, and podcasts.

In 2017, co-founded the Alternative Energy Popular Education Programme. ALTEPEP was born as one of the three programmes under the “Student consciousness” project run under the Centre for Policy and Development (CEPD). At its minimum, the concept for the Alternative Energy Popular Education Programme aims to make use of critical pedagogy methodologies to facilitate transdisciplinary spaces between school going youth, university and TVET students along with community activists in dialogue on questions of energy as it relates to production, service provision, ownership and “work” with a focus on renewable energies.

I served as a Director and Associate Researcher between 2017-2021 where I led the research program on Profit Shifting and the Consequences of Illicit Financial Flows in Africa by exploring the relationship between extractives, illicit financial flows, and climate minerals for the transition to a low-carbon economy. I organised and coordinated a range of workshops, summer/winter schools, podcast series, and translating these to active interventions through community garden solar installation programmes and other co-operative based initiatives for self-reliance.

Before my academic research, I was a researcher for a Cape Town based labour and social movement support organisation. I worked at the Alternative Information and Development Centre where I lobbied for measures to combat tax evasion, base erosion and profit shifting. Working on the Economic Justice program, I worked on the Stop the Bleed Campaign – a metaphor for illicit financial flows and money lost through tax avoidance schemes. I advocated efforts for legislative reform, drafted parliamentary submissions on anti-avoidance tax legislation, worked with unions on litigating action, and I began research and lobbying around mining taxation and corporate accountability. In 2019, I was part of a team supporting an investigation of transfer pricing leading up to the litigation of the second largest chrome producer in the world, Samancor, by the Association of Mineworkers and Construction Union. The mining company was being litigated for allegedly engaging in transactions outside the arms-length principle by using its subsidiary located in the British Virgin Islands as a front for Samancor’s directors and majority shareholders. These transactions dating from 2005 allegedly included illicitly shifting funds offshore through transfer pricing, marketing agreements involving secret consulting, commission and facilitation fees, unapproved debt write-offs, secret corporate restructuring arrangement through a range of share purchases and disposals, and spurious management fees. All told, $1,9 billion was alleged to have been lost through these arrangements.

I became intrigued by the relationship between the fact that more than half of the countries in the Caribbean did not attain political independence, and that a significant number of these went on to develop as tax havens. Britain, which was the dominant imperial power in the region, has close political ties to thirty of the sixty tax havens, accounting for 37% of global banking liabilities and assets. While there was research being done linking tax havens to corruption and the shifting of profits, I couldn’t find a lot about their developmental history as nation states and how these island territories came to assume their function in the global political economy. I wanted to reflect on the aspirations of an equitable international taxation regime by exploring the factors tracing the development of tax havens as non-sovereign nation states. How did non-sovereign states resolve the tension of pursuing autonomous development as colonial dependencies? This puzzle became the galvanising force of my MA thesis.

Behind this inquiry lay the promise of casting new light on a chronic problem: natural-resource rich countries with high levels of poverty and underdevelopment. Africa has been a net-creditor to the world: with an external debt of $258 billion in 2008, Africa recorded capital outflows of $579 billion to $1,4 trillion due to profit shifting and tax evasion between 1980 and 2009. To appreciate the relationship between extractives, profit shifting, and the challenge of curbing the use of tax haven jurisdictions, it is important to understand the developmental history of offshore centres and their particular paradox as non-sovereign states. This rationale built on the work of my Honours thesis where I looked at mineral rich countries with high underdevelopment using the DRC as a case study. I used one of the only two tax treaties internationally in force with the DRC to explore the source and residence conflict in international taxation by investigating if there is a link between reduced taxing rights and increased foreign direct investment anticipated to aid poverty reduction. I paired a legal doctrinal comparative analysis of the contradictions between the income Distributive Rules Articles of the United Nations Model Tax Convention and the South Africa-Democratic Republic of Congo Double Tax Treaty with a correlation study of the FDI inflows to the DRC after the tax treaty with South Africa came into force in 2013.

Thereafter, I was a finalist and the regional runner-up of the 2018 Ernst and Young (EY) Young Tax Professional of the Year award. I had been signed with EY for my accounting and auditing articles throughout the duration of my undergraduate studies. EY had spotted me through a Talent Recruitment Program, awarding me funding for by Bachelor’s in ny final high school year on the condition that I would serve my articles at EY after I completed my honours. So, I was contractually bound to begin my articles. However, I could not reconcile the bursary conditions with my core aspirations.

During my investigation into the transfer pricing of mining companies shifting profits to tax havens in the Caribbean, I wanted to understand how profit shifting impacted marginalised and precarious artisanal miners who unearth the minerals. Moreover, I wanted to approach the broader field of international taxation through an historical lens of empire, nation building, globalisation, sovereignty and decolonisation. I acknowledged the theoretical and methodological constraints of the Finance and Tax discipline for the work I wanted to do. Consequently, I enrolled for a newly launched interdisciplinary Master of Philosophy specialising in Theories of Justice and Inequality, a program housed in the UCT Sociology Department, and I was in the program’s first cohort of students.

My MA training enabled me to use innovative theoretical frameworks with historiographical research techniques. I took courses in Political Sociology and Global Political Thought to broaden my theoretical arsenal. I complemented these modules within a History and Anthropology based Centre for African Studies Department which offered a Problematising the Study of Africa course to sharpen my methodological tools. Before the covid-19 pandemic restricted international travel, I had planned to submerge myself in the world of artisanal and informal miners in the DRC for my MA research. With travel and fieldwork out of the question, I relied on archival document analysis and pivoted my master’s dissertation to historically situate non-sovereign tax havens in international taxation by using the minutes of the British Virgin Islands Legislative Council.

My Master’s dissertation on Reconstituting Empire in the Decolonisation Era used taxation sovereignty as a lens through which I constructed a critical review of the developmental history of the British Virgin Islands. Drawing on a combination of sociology and law scholarship alongside a review of the BVI Legislative Council minutes from 1950-1993, I used a sociolegal approach to chart the significance of ‘tax’ sovereignty – the “right” or jurisdiction of the state to impose tax. I traced the political-sociological developments of the 1950 independence decade which accompanied BVI’s version of decolonisation, followed by a phase of “neo-colonial imperialism” which tracked the socioeconomic and legislative developments corporatizing sovereignty from 1960 to 1984. This illustrated the conditions which generated reliance and external dependence on a reconstituted form of empire.

Toward the end of writing my master’s dissertation, which I completed just before the spring of 2021, I joined the Justice for Miners Campaign as the advocacy and lobbying impact leader. My role was to advocate legal reform of the compensation system by guiding the actions to lobby statutory bodies and mining companies. Before adjourning my position, I briefly helped mould these lobbying efforts to secure the campaign objectives. I coordinated JFM campaign actions and directed efforts to combine its forces at a regional level through initiating measures to strengthen the organisational and mobilising capacity of its six chapters across five countries in Southern Africa. This culminated in formulating a cohesive set of campaign tactics to ensure the just compensation for an estimated initial 500 000 potential claimants who contracted silicosis and tuberculosis working the gold mines of South Africa between 1965 and 2019.

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   • Rakei, S. (2019). “Writing on Water: The Haitian Revolution and Universal History.” POL5048S Global Political Thought. Political Studies Department, University of Cape Town.
     Available at Simon Rakei: https://simonrakei.wordpress.com/2019/08/02/writing-on-water-the-haitian-revolution-and-universal-history/
     
     
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