Industrial Policy & Trade Monitor· 2666 actions· ✨ 90 recent

Zambia enacted the Income Tax (Amendment) (No. 2) Act No. 17 of 2025, assented to 23 December 2025 and effective 1 January 2026, introducing two mining-specific fiscal provisions. First, interest deductibility is capped at 30% of tax EBITDA for all companies, with unrelieved interest carry-forwardable for up to five years (general) or ten years for entities in mining and electricity generation. Second, mining companies deriving at least 75% of gross income in foreign exchange from outside Zambia may maintain their books of accounts in US dollars, reducing FX translation risk for dollar-denominated operators. Both measures are structurally distinct from the concurrent Act No. 10 of 2025 (Minimum Alternative Tax and loss carry-forward cap).

On 12 December 2025 the Finnish Parliament (Eduskunta) approved Act 1361/2025, amending the Mining Minerals Tax Act (kaivosmineraalivero- laki, Act 314/2023) on the basis of government bill HE 127/2025. The amendment raises the value-based royalty on taxable metals contained in mined metallic ores from 0.6% to 2.5% (a 4.2× increase) and lifts the tonnage royalty on industrial minerals and other useful rock from €0.20 to €0.60 per tonne (3× increase). Iron is newly added to the list of taxable metals (alongside silver, gold, cobalt, chromium, copper, lithium, nickel, lead, palladium, platinum, uranium and zinc). Tax revenue is split 80% to the state and 20% to mining municipalities. The amendment enters into force on 1 January 2026.

Zambia's Statutory Instrument No. 68 of 2025 under the Geological and Minerals Development Act 2022 establishes the first binding procurement-quota local-content regime in the Zambian copper-cobalt mining sector, entering into force 1 January 2026. Mining and mining-related companies must reserve a minimum 20% of their annual procurement budget for Zambian-owned or citizen-empowered suppliers of core mining goods and services, escalating to 25% in year two and 35% in year three, targeting 40% within five years. All non-core ancillary services (catering, security, haulage, cleaning, gardening) are reserved exclusively for Zambian-owned companies. The instrument operationalises the Minerals Regulation Commission created under the 2024 MRC Act and completes the ZM resource-nationalism statute stack.

The Bank of Zambia formally accepted Chinese renminbi (RMB/CNY) for copper and cobalt mining royalty and tax payments starting October 2025, making Zambia the first African country to establish an official RMB settlement channel for mining fiscal flows. In December 2025 the BoZ began publishing an official RMB-kwacha exchange rate to enable precise royalty and corporate tax calculations. The central bank cited efficiency grounds: Chinese mining companies operating Zambia's largest copper producers already receive export revenues in yuan from Chinese off-takers, making yuan-denominated tax settlement a natural extension that also reduces Zambia's Chinese-debt servicing friction. The policy embeds Chinese currency infrastructure into the sovereign fiscal architecture governing Zambia's copper and cobalt supply chain, deepening structural alignment between Zambia's resource sector and China's commodity-import ecosystem.

Zambia enacted the Income Tax (Amendment) Act No. 10 of 2025 on 8 August 2025, gazetted 19 August 2025, introducing three interlocking fiscal measures. First, a 1% Minimum Alternative Tax (MAT) on annual turnover applies to all companies and partnerships, creditable against standard income tax with a five-year carry-forward — directly raising the floor tax burden on large copper and cobalt mining groups that have historically reported low taxable profits. Second, the 50% annual loss carry-forward cap (previously mining-sector-specific) is universalised, reducing the tax-shelter advantage for capital-intensive mining projects with front-loaded losses. Third, withholding tax on government-securities interest is raised from 15% to 20%.