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Mining Tax and Strategy Masterclass

2 Day Training

Dates: 09 – 10 October | 12 – 13 November 2024
Locations: Johannesburg, South Africa
Platform: Available In-Class / Online

Price: Available on Request

Course Introduction

Mining Tax and Strategy Masterclass: Mines serve a dual purpose, generating profits for shareholders and investors while also benefiting the broader economy. Many mining operations closely monitor seven key economic and financial factors, often structuring their departments around these critical aspects. Neglecting to develop a strategic approach to managing mining taxes can be detrimental, potentially leading to the downfall of emerging mining companies. Surprisingly, even well-established mining companies have faced severe setbacks due to inadequate tax strategies.


The nature of profit generation and tax treatment varies significantly throughout the various stages of a mine’s life cycle. Factors such as changes in product control, alterations in mining leadership, and shifts in ownership further complicate the tax landscape. Everyday decisions made in mines and boardrooms play a pivotal role in shaping profit trajectories and, consequently, tax obligations.


Across diverse commodities and regions in South Africa, encompassing both open-cast and underground mines, exploration endeavors, and mining companies, there is a concerted effort to maximize profits. Paradoxically, many of these efforts are counteracted by ineffective responses to managing tax liabilities. Tax strategies vary widely, leading to varying outcomes. Governments worldwide utilize taxation as a means to generate revenue and influence corporate behavior.


For mining companies, approximately 50% of their tax burden is related to income tax, with an additional ±30% of taxes specific to the mining sector. In the short term, governments can secure substantial tax revenues from existing mining companies in South Africa. However, such policies may hinder their growth and discourage potential investments from new companies seeking to enter the market.

Course Objectives

By the end of the Mining Tax and Strategy Masterclass course, participants should have a thorough understanding of the intricate tax landscape within the mining industry and the strategies required to navigate it effectively to optimize profitability and compliance.Top of Form

  • Gain Insight into Profit Drivers in the Mining Sector

  • Understand Key Definitions, Concepts, and Terms

  • Navigate Base Erosion & Profit Shifting (BEPS) and Transfer Pricing

  • Explore Carbon Tax Implications

  • Delve into Contractor Engagement and Tax Treatment

  • Understand Mineral Inventory Management and Tax Implications

  • Navigate Diesel Rebate Regulations

  • Explore Rehabilitation Trusts and Tax Considerations

  • Gain Insights into the Mineral and Petroleum Resources Royalty Act

  • Analyse Mining and Prospecting Rights Transactions

  • Develop a Strategic Profit and Tax Planning Framework

Who should attend?

  • Mine Accountants

  • Financial Controllers and Supervisors

  • Members of On-Mine Cost-Cutting Teams

  • Experienced Finance Professionals New to the Mining Sector

  • Finance Managers and Supervisors

  • Business and Profit Strategists

  • Directors of Mining Companies

  • Legal Compliance Managers of Mines

  • Individuals Dealing with Mining Tax

Finance Courses

Training Methodology

Our diverse instructional approaches ensure effective learning:

– Lectures & Presentations: Engage with expert-driven, stimulating content.
– Course Material: Access well-crafted supporting resources.
– Group Work: Collaborate on discussions and case studies for practical insights.
– Workshops & Role-Play: Participate in immersive, scenario-based activities.
– Practical Application: Focus on applying theoretical knowledge in real situations.
– Post-Training Support: Receive extensive support after training for skill implementation.

Training Outline

Day 1:

Session One: Mining Sector Profit Drivers

  • Explore internal and external factors that drive profitability in the mining sector.

  • Discuss strategies for leveraging profit drivers with a small team.

Definitions, Concepts, and Terms

  • Emphasize the need for specialized treatment of the Mining Sector.

  • Examine key regulations such as the MPRDA (Mineral and Petroleum Resources Development Act) and the Income Tax Act.

  • Distinguish between Income Tax and Mining Tax.

  • Highlight the unintended consequences of poor decision-making.

Session Two: Definitions, Concepts, and Terms (Continued)

  • Define crucial terms including Gross Income, Minerals, Mining, and Mining Operations.

  • Examine the point at which mining transitions into manufacturing, impacting liabilities.

  • Draw insights from relevant case law in the mining industry.

Session Three: Mining and Non-Mining Income

  • Determination of Mining Income

  • Determination of and Rules of Non-Mining Income

  • Pre-Mining and Post-Mine Closure Income

  • Case Law and Strategy

Exercise: When is Dump Retreatment a Mining Operation and when is it not

Course Content (Continued):

Session Four: Base Erosion & Profit Shifting (BEPS) and Transfer Pricing

  • Review permissible Transfer Pricing methods.

  • Address the treatment of Management and Marketing Expenses and determining their limits.

Session Five: Carbon Tax

  • Discuss the emergence and future implications of Carbon Tax in the mining sector.

  • Cover the calculation, reporting, and reduction of Carbon Tax.

Session Six: Contractors and Mining

  • Analyze the trend toward Contract Mining.

  • Compare income options: Rental, Royalty, or Revenue Sharing.

  • Examine the tax treatment of Contract Mining and relevant case law.

Engage in an exercise on equipment lease and buyback.

Day 2:

Session Seven: Mineral Inventory

  • Define what constitutes inventory in the mining context.

  • Differentiate between Inventory, Stockpiles, and Trading Stock.

  • Explore relevant case law and strategic considerations related to mineral inventory.

Session Eight: Diesel Rebate

  • Trace the historical evolution of the diesel rebate.

  • Identify common mistakes in claiming the rebate and provide strategies for overcoming them.

Session Nine: Rehabilitation Trusts and Tax

  • Define Closure Costs and strategies for their reduction.

  • Offer an illustrative example of Closure Cost calculation.

  • Address issues of overpayment and underpayment.

Conduct an exercise on the treatment of stockpiles.

Course Content (Continued):

Session Ten: Mineral and Petroleum Resources Royalty Act

  • Explore government policies regarding royalties.

  • Examine concepts outlined in the Royalty Act.

  • Break down the Royalty Act Formulae.

  • Discuss whether royalty is considered a tax or a levy.

  • Investigate relevant case law and strategic considerations.

Participate in an exercise related to Management & Marketing Expenses.

Session Eleven: Mining & Prospecting Rights

  • Analyze scenarios involving the acquisition, sale, or trading of mining and prospecting rights.

  • Explore tax implications arising from various treatment options.

Session Twelve: Strategic Planning

  • Conclude the course with a discussion on the importance of developing a profit and tax strategy when departing from the program.

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