Chapter 08
Tax, Royalties & Compliance
You will rarely pay these levies directly as a foreign buyer, but they shape producer economics, export incentives and the landed price — so a serious buyer understands them. And compliance obligations reach buyers, not just miners.
The fiscal regimes
Zambia levies copper mineral royalty on a price-banded scale, applied incrementally: 4% below US$4,000/t, rising through 6.5% and 8.5% to 10% at or above US$7,000/t. At today’s prices, the top band bites. Mining corporate income tax is 30%. The DRC’s 2018 code set copper (a base metal) at 3.5%, a 10% royalty on ‘strategic’ minerals such as cobalt, doubled the state’s free-carried interest to 10%, and shortened fiscal stability to five years.
| Lever | Zambia | DR Congo |
|---|---|---|
| Copper royalty | 4% → 10% sliding (10% now) | 3.5% flat (base metal) |
| Strategic-mineral royalty | 8% cobalt | 10% (cobalt, germanium, coltan) |
| State interest | ZCCM-IH equity stakes | 10% free-carried, non-dilutable |
| Corporate income tax | 30% (mining) | 30% (mining) |
| Fiscal stability | No statutory stabilisation | 5 years |
Compliance & due diligence
The Copperbelt sits inside one of the world’s most scrutinised mineral supply chains. The frameworks you must know:
- 1OECD Due Diligence Guidance. The global baseline — trace material to the smelter/refiner and manage risk along the chain.
- 2US Dodd-Frank §1502. The DRC and nine neighbours, including Zambia, are ‘covered countries’. Copper was added to the EMRT 2.0 template in 2025, so provenance is now in scope for many downstream buyers.
- 3OFAC sanctions screening. Screen every counterparty and beneficial owner. A single tainted party can poison a transaction.
- 4EITI transparency. Both countries participate — useful for verifying licences and payments.
- 5Artisanal vs industrial. The DRC now strictly separates the two and bans mixing. Insist on industrial, traceable origin.
Company registration & export licence (verified with the regulator, not just a PDF) · beneficial-ownership map · sanctions / PEP screening · proof the seller controls the specific metal (warehouse receipt, title, mine linkage) · independent inspection rights · bank references.