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

On 18 February 2025 Tailings Dam 15 at Sino-Metals Leach Zambia Limited's Chambishi facility (Copperbelt Province, Kalulushi District) failed, releasing acidic leach residue into the Chambishi Stream and the Mwambashi and Kafue Rivers; the company suspended operations and the Zambia Environmental Management Agency (ZEMA) commissioned an independent Environmental and Social Incident Impact Assessment (ESIIA). ZEMA received the consultant's final report on 19 December 2025 and held a public disclosure meeting in Kitwe on 6 January 2026. On 2 February 2026 the Ministry of Mines and Minerals Development announced that the investigation had concluded and that, once ZEMA's review of the findings is complete, stakeholders will be engaged to determine remediation and compensation modalities. Company clean-up operations began in March 2026.

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).

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%.

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 Minerals Regulation Commission Act, No. 14 of 2024 repeals and replaces Zambia's 2015 Mines and Minerals Development Act in its entirety, establishing a new autonomous Minerals Regulation Commission (MRC) as the country's central mining-sector regulator together with a standalone Mining Appeals Tribunal. The Act restructures licensing, royalty administration, monitoring and enforcement, and creates a dedicated dispute-resolution architecture separating regulatory and adjudicatory functions. Assented to on 20 December 2024 and gazetted on 26 December 2024, the Act took effect on 13 June 2025 pursuant to the Minerals Regulation Commission Act, 2024 (Commencement) Order, 2025 (SI 42 of 2025) signed by the Minister of Mines and Minerals Development on 3 June 2025.

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.