Zambia is one of the largest producers and exporters of copper in Africa. Mining is a major economic sector in the country, contributing significantly to Zambian government revenues, mainly through mining royalties and value-added tax. Zambia’s mining sector scores “weak” in the Resource Governance Index 2017.

Main Mining Products

  • Cobalt
  • Copper
  • Emeralds
  • Manganese

What Are We Doing in Zambia?

We are working with Zambia’s revenue and mining ministries to improve revenue collection from the mining industry.

Legal and Policy Support

We advised Zambia on revising its transfer pricing rules to prevent the profits from the sale of copper from being shifted overseas to low-tax jurisdictions.


We have given trainings on copper and manganese pricing, financial transactions, and transfer pricing in the mining sector. We have also helped establish an inter-agency working group on mineral pricing that is developing a risk assessment framework for manganese and copper pricing.

We finalized two internal guidance documents that Zambia’s revenue authority has adopted. One is designed to help officials value mining licences for property transfer tax purposes, and the other focuses on royalty apportionment in cases where royalties must be collected from companies that blend and process materials mined by a third party with their own mined material.

Audit Support

We continue to support Zambia’s revenue agency on audits and have contributed to three transfer pricing audits in the mining sector.

Ignatius Mvula“The training on transfer pricing risk assessment in the mining sector was very useful and practical, reflecting actual issues encountered by auditors.”

Ignatius Mvula, Head of the Mining Audit Unit, Zambia Revenue Authority