Executive Mining Tax Strategy Masterclass

The programme

Programme overview

Executive Mining Tax Strategy 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 Executive Mining Tax Strategy Masterclass 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.

Who should attend

Who is this programme for?

• 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)

Learning outcomes

What you will learn

• 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
• 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, informed by current case law
• Balances tax optimisation with ethics and governance
• Prepares executives for real decisions, not theoretical compliance

Executive Learning Outcomes

• 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, informed by current case law
• 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

Explore the programme

Detailed programme outline

• The mining tax value chain
• Where tax is created, lost, or disputed
• Why mining is a SARS priority sector
• Incorporation vs branch vs JV
• Place of effective management (PoEM)
• Holding companies, SPVs, and substance
• Exploration vs development vs production
• Stripping, waste removal, care & maintenance
• Beneficiation boundaries
• Accounting policy choices
• Estimates, provisions, impairments
• IFRS–tax alignment
• Debt vs equity
• Shareholder loans
• Streaming and royalty finance
• Commodity pricing
• Marketing hubs
• OECD BEPS and Pillar Two
• Growing SARS scrutiny of cross-border structures under Section 9D of the Income Tax Act (controlled foreign company rules), given mining groups' reliance on cross-border financing and investment structures
• Royalty base disputes
• Carbon tax allowances and offsets, at the current rate of R308 per tonne of CO2 equivalent effective from 1 January 2026, with treatment of carbon tax, emissions reporting, and related allowances as core components of tax governance and climate transition planning
• Rehabilitation trusts
• Community and environmental spend
• Asset vs share deals
• JVs, farm-ins, distressed acquisitions
• Audit selection and information requests
• Objections, ADR, and litigation
• Current case law: the Supreme Court of Appeal's landmark 9 April 2026 judgment in the Glencore/ARM Coal diesel refund dispute, clarifying ‘possession of a mining right’ for VAT-registered mining joint ventures and setting a significant precedent for JV structuring and dispute strategy
• King IV tax governance
• Director and officer liability

Learning approach

How you will learn

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.

Discuss your requirements

Dates, duration & arrangements

Contact Ratomac to confirm dates, duration, delivery format, entry requirements and any applicable assessment or certification before booking.