Industrial Policy & Trade Monitor· 2663 actions· ✨ 89 recent

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.