| Date | Venue | Duration | |
|---|---|---|---|
| 24 - 26 August 2026 | Pretoria | 3 Days | |
| 19 - 21 October 2026 | Sandton | 3 Days | |
| 10 - 12 November 2026 | Sandton | 3 Days |
Tax Strategy for Miners™ is a first-of-its-kind executive programme designed specifically for senior finance leaders in the mining sector. It responds directly to the increasing complexity of mining taxation, heightened SARS enforcement, ESG scrutiny, and board-level accountability.
This programme is not a technical tax update. It is a strategic, decision-focused programme that equips executives to anticipate tax consequences, structure transactions intelligently, manage SARS engagements, and eliminate tax leakage—while maintaining ethical integrity and regulatory defensibility.
To equip senior mining finance leaders with the capability to design, govern, and defend tax strategies across the full mining business model, by understanding:
Where tax value is created and lost
How SARS interprets mining operations and transactions
How to optimise cash flow ethically and sustainably
How to lead audits, disputes, and board-level tax decisions
Prospen Africa’s Tax Strategy For Miners’ Masterclass uniquely:
Reviews the entire mining life cycle as a tax system
Identifies all major tax leakage points across operations, financing, ESG, and transactions
Mirrors SARS audit logic and dispute behaviour
Balances tax optimisation with ethics and governance
Prepares executives for real decisions, not theoretical compliance
It is designed to close the gap between mining operations, IFRS reporting, tax law, and SARS enforcement reality.
By the end of the Tax Strategy For Miners’ programme, participants will be able to:
Identify and eliminate tax leakage across the mining life cycle
Structure mining entities, operations, and transactions for optimal after-tax outcomes
Anticipate SARS audit positions and manage disputes strategically
Align IFRS, operational decisions, and tax outcomes coherently
Optimise mining cash flows through incentives, deductions, and exemptions
Balance tax optimisation with ethics, ESG, and governance obligations
Protect themselves and their boards from personal tax exposure
This Tax Strategy For Miners’ Masterclass is designed for senior decision-makers, including:
Chief Financial Officers (CFOs)
Deputy CFOs
Group Financial Controllers
Heads of Tax (Mining)
Senior Finance Managers
Senior Commercial and Strategy Executives with tax accountability
Senior Internal Audit and Risk Executives (Mining-focused)
This course is not for junior staff or an entry-level tax training.
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.
Session 1 – THE MINING TAX SYSTEM & STRUCTURAL FOUNDATIONS
Module 1: Reframing the Mining Business Model as a Tax System
The mining tax value chain
Where tax is created, lost, or disputed
Why mining is a SARS priority sector
Module 2: Incorporation, Corporate Residence & Ethical Group Design
Incorporation vs branch vs JV
Place of effective management (PoEM)
Holding companies, SPVs, and substance
Session 2 – OPERATIONS, IFRS & CORE TAX LEAKAGE
Module 3: Mining Operations as SARS Classifies Them
Exploration vs development vs production
Stripping, waste removal, care & maintenance
Beneficiation boundaries
Module 4: IFRS as a Tax Signal and Defence Tool
Accounting policy choices
Estimates, provisions, impairments
IFRS–tax alignment
Session 3 – FINANCING, CROSS-BORDER STRUCTURES & NON-INCOME TAXES
Module 5: Financing Mining Operations Without Tax Leakage
Debt vs equity
Shareholder loans
Streaming and royalty finance
Module 6: Transfer Pricing, Marketing Hubs & BEPS Pressure
Commodity pricing
Marketing hubs
OECD BEPS and Pillar Two
Session 4 – ESG, TRANSACTIONS & GOVERNANCE
Module 7: Royalties, Carbon Tax & Cash-Flow Taxes
Royalty base disputes
Carbon tax allowances and offsets
Module 8: ESG, Rehabilitation & Ethical Tax Boundaries
Rehabilitation trusts
Community and environmental spend
Module 9: Mining Transactions, Restructuring & Exit
Asset vs share deals
JVs, farm-ins, distressed acquisitions
Session 5 – SARS, DISPUTES & EXECUTIVE ACCOUNTABILITY
Module 10: SARS Audits, Disputes & Executive Strategy
Audit selection and information requests
Objections, ADR, and litigation
Module 11: Tax Governance, Ethics & Personal Exposure
King IV tax governance
Director and officer liability
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