Industrial Policy & Trade Monitor· 2662 actions· ✨ 89 recent

Zambia's Ministry of Commerce, Trade and Industry gazetted Statutory Instrument No. 17 of 2026 on 20 March 2026 (effective 27 March 2026), replacing a prior outright export prohibition on sulphuric acid with a permit-based export control regime under the Control of Goods Act (Chapter 421). The instrument was triggered by an acute domestic shortage after multiple major Zambian copper smelters entered simultaneous extended maintenance shutdowns in 2025, collapsing by-product acid production. As the dominant supplier of sulphuric acid to DRC hydrometallurgical copper and cobalt mines, Zambia's restriction disrupted leaching operations across the DRC's oxide-ore processing chain. A partial easing began in May 2026 as smelter capacity recovered, with company-specific export authorisations issued to Chambishi Copper Smelter and Mopani Copper Mines.

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).

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%.

Zambia's Parliament enacted the Property Transfer Tax (Amendment) Act No. 27 of 2024, assented to by President Hichilema on 24 December 2024 and in force from 1 January 2025. The Act introduces a first-ever dedicated Property Transfer Tax (PTT) schedule for mining rights: 10% of realised value on transfers of mining licences and mineral processing licences, and 8% on transfers of exploration licences. The measure directly raises the transaction cost of copper and cobalt mine acquisitions, stake transfers, and licence assignments across the Zambia Copperbelt. It is the fifth distinct fiscal or governance instrument enacted since 2024 in Zambia's rolling reform of its mining regulatory architecture.

The Mines and Minerals Development (Amendment) Act, No. 29 of 2022 restructures Zambia's Mineral Royalty Tax (MRT) on copper from a flat rate to a four-band price-linked sliding scale, effective 1 January 2023. Under the new regime, copper royalties range from 4% of norm value when the LME price is below USD 4,000/tonne to 10% when prices exceed USD 7,000/tonne — at prevailing LME copper prices (~USD 9,000–10,000/t in 2024–2026), the effective rate is 10%, one of the highest copper royalty rates in the global copper belt. The Act also codifies flat royalty rates for other base metals (5%), gemstones (6%), and precious metals (6%), and abolishes the prior flat-rate copper royalty that applied regardless of commodity-cycle position, materially increasing state rent capture in high-price environments while preserving a 4% floor for project viability at low prices.

The Income Tax (Amendment) Act, 2021 (Act No. 43 of 2021), assented 30 December 2021 and in force from 1 January 2022, re-introduces the deductibility of Mineral Royalty Tax (MRT) paid under the Mines and Minerals Development Act, 2015 when computing a mining company's taxable income for corporate income tax purposes. The Act removes mineral royalty from the list of non-deductible expenditures in section 44 of the Income Tax Act, reversing a non-deductibility rule that had applied since a 2015-era amendment and that mining companies and industry stakeholders had argued produced double taxation of the same revenue stream. Deductibility is conditional on the royalty having actually been paid for the charge year.