South Africa: Recommendations for changes to mining taxation

South Africa: Changes to mining taxation

The “Davis Tax Commission” released its first interim report on mining taxation, and comments are due by 31 October 2015. The report is only provisional, and includes a review of the current mining tax regime in South Africa. The report focuses on traditional mining (including royalty taxes). It does not cover the oil and gas sectors (which will be the subject of a separate report, to be issued later).


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Among the recommendations proposed in the report are the following:

  • Repeal of the 100% upfront capital deduction granted to mining taxpayers
  • Repeal of the current ring-fencing provisions 
  • Repeal of the gold mining formulae and phase-out of the current indexation allowances available to gold mines
  • Proposal for a possible tax allowance for mining rights in the form of a depletion allowance
  • Allow all infrastructure costs incurred in terms of a mine’s social and labour plan (SLP) as a tax deduction
  • Removal of section 37 of the Income Tax Act

The current royalty regime would be continued, and would not be replaced with any windfall or rent resource taxes. 

Recommendations in a later version of the report are expected to concern the determination of the gross sales tax base.



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