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Zambia's Mines and Minerals Development Act, 2015 introduced a flat Mineral Royalty Tax on mining revenue that, from that point, was explicitly excluded from the list of deductible expenses under section 44 of the Income Tax Act — meaning mining companies paid MRT on gross revenue and then paid corporate income tax on profits calculated without deducting that royalty, a structure industry groups (including the Zambia Chamber of Mines) characterised as double taxation of the same mineral-extraction revenue. This Act reverses that treatment: from the 2022 charge year, MRT paid under the MMDA is an allowable deduction in ascertaining a mining company's gains or profits for income tax purposes, so long as the royalty was actually paid in the charge year it relates to.
This is a distinct instrument from the 2022-12-27 Mines and Minerals Development (Amendment) Act No. 29 of 2022, which restructured the rate of MRT on copper into a price-linked sliding scale — that Act amends the Mines and Minerals Development Act and sets how much royalty is owed; this Act amends the Income Tax Act and governs whether royalty already paid can be deducted from taxable income. Both sit in the same policy lineage of Zambia recalibrating mining-sector rent capture, but move in opposite directions: the 2022 Act raised the effective royalty burden at high copper prices, while this 2021 Act lowers the net effective tax burden by eliminating double taxation of the royalty itself.
relative to the 2015-2021 non-deductible regime, partially offsetting the burden later added by the 2022 sliding-scale royalty increase.
investment through fiscal relief, ahead of the subsequent 2022-23 royalty-rate tightening — useful context for reading the MRT sliding-scale Act as a partial reversal of this relief rather than a standalone escalation.
mining-fiscal instrument on file was dated 2022-12-27).
the deductibility condition; not identified in this filing's sourcing.