Mining Tax Compliance and Technical Masterclass

The programme

Programme overview

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 maximise 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 utilise taxation as a means to generate revenue and influence corporate behaviour.

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.

Who should attend

Who is this programme for?

• 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

Learning outcomes

What you will learn

• 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, including the Phase 2 changes effective from 1 January 2026
• Delve into Contractor Engagement and Tax Treatment
• Understand Mineral Inventory Management and Tax Implications
• Navigate Diesel Rebate Regulations, including the 100% refund now available to qualifying mining operations from 1 April 2026
• 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

Explore the programme

Detailed programme outline

1-Day Essentials — Training Outline

• Internal and external factors driving profitability in the mining sector
• Key regulations: the MPRDA and the Income Tax Act
• Distinguishing Income Tax and Mining Tax; mining vs. non-mining income
• Crucial definitions: Gross Income, Minerals, Mining, and Mining Operations
• Carbon Tax Phase 2, effective 1 January 2026, now covering all sectors including previously excluded major polluters
• Current rate: R308 per tonne of CO2 equivalent (up from R236), on a legislated path to R462/tCO2e by 2030
• Tax-free allowances decreasing by 10 percentage points in 2026; the Carbon Budget Allowance phased out from January 2026, with emissions exceeding carbon budgets taxed at R640/tCO2e
• Calculation, reporting, and reduction strategies
• Historical evolution of the diesel rebate
• SARS's 13 February 2026 announcement: effective 1 April 2026, qualifying mining operations (alongside farming and forestry) may claim a 100% refund on eligible diesel used in qualifying activities, up from the previous rate
• Common mistakes in claiming the rebate and strategies for overcoming them
• Government policies regarding royalties and core Royalty Act concepts
• Whether royalty is considered a tax or a levy
• Developing a profit and tax planning framework to take back into your organisation

2-Day Comprehensive — Training Outline

• Explore internal and external factors that drive profitability in the mining sector
• Discuss strategies for leveraging profit drivers with a small team
• Emphasise the need for specialised treatment of the Mining Sector
• Examine key regulations such as the MPRDA and the Income Tax Act
• Distinguish between Income Tax and Mining Tax
• Highlight the unintended consequences of poor decision-making
• 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
• Determination of Mining Income
• Determination of and rules of Non-Mining Income
• Pre-Mining and Post-Mine Closure Income
• Case Law and Strategy
• Review permissible Transfer Pricing methods
• Address the treatment of Management and Marketing Expenses and determining their limits
• Carbon Tax Phase 2, effective 1 January 2026, now covering all sectors
• Current rate: R308 per tonne of CO2 equivalent, on a legislated path to R462/tCO2e by 2030
• Tax-free allowances decreasing by 10 percentage points in 2026; Carbon Budget Allowance phased out from January 2026, with excess emissions taxed at R640/tCO2e
• Calculation, reporting, and reduction of Carbon Tax
• Analyse the trend toward Contract Mining
• Compare income options: Rental, Royalty, or Revenue Sharing
• Examine the tax treatment of Contract Mining and relevant case law
• 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
• Trace the historical evolution of the diesel rebate
• SARS's 13 February 2026 announcement: effective 1 April 2026, qualifying mining operations may claim a 100% refund on eligible diesel used in qualifying activities, up from the previous rate
• Identify common mistakes in claiming the rebate and provide strategies for overcoming them
• Define Closure Costs and strategies for their reduction
• Offer an illustrative example of Closure Cost calculation
• Address issues of overpayment and underpayment
• 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
• Analyse scenarios involving the acquisition, sale, or trading of mining and prospecting rights
• Explore tax implications arising from various treatment options
• Conclude the course with a discussion on the importance of developing a profit and tax strategy when departing from the program

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.