Industrial Policy & Trade Monitor· 2674 actions· ✨ 91 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).

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%.