BEPS in Mining Case Study: Boosting Zambia’s revenues from the sale of manganese and copper

African Tax Administration Forum • August 17, 2020

This case study outlines some steps that Zambia has taken to improve revenue collection from the mining sector, with support from the African Tax Administration Forum (ATAF), the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF), and the Organisation for Economic Co-operation and Development (OECD).

  • We (ATAF, IGF, and OECD) helped Zambia improve its methodology for valuing manganese ore.
  • We worked with Zambia to revise their transfer pricing rules to prevent the profits from the sale of base or precious metals from being shifted overseas to low-tax jurisdictions.
  • We provided assistance in transfer pricing risk assessment and on Zambia Revenue Authority (ZRA) audit cases.

This support comes from our BEPS in Mining Program, which takes a whole of-government approach to address critical mining revenue issues. We are working with Zambia’s Ministry of Mines, Ministry of Finance, and the ZRA in all program activities, including trainings for government officials.

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