Mining Tax Tanzania: The Full Tax and Levy Stack

Mining tax Tanzania questions rarely stop at royalty. A producing mine on the Mainland pays charges to at least four collectors: the Mining Commission, the Tanzania Revenue Authority (TRA), the district council and the social security funds. The Government also holds a free carried interest in the company itself.

This guide sets out each charge, its rate, its base, the law behind it and the line in the Zatra fee register that records it. It then works the numbers for a gold company with TZS 50 billion of gross value. Royalty mechanics are covered in our mineral royalty and inspection fee guide, so this post links there rather than repeating them.

What the law says

Four statutes carry most of the load.

• The Mining Act, Cap. 123. It sets royalty, the inspection fee, the HIV Response Levy, the gold set-aside and the Government's free carried interest. Section 2 of the TanzLII consolidation of the Mining Act to 30 November 2019 says the Act applies to Tanzania Mainland. The Mining Commission also publishes a copy of the Act on its website.
• The Income Tax Act, Cap. 332 R.E. 2023. Division IV of Part V, sections 66 to 75, holds the mining rules. Section 68 deals with separate mining operations, section 71 with losses from mining operations and section 73 with realisation of mineral rights. TRA publishes the Revised Edition 2023 of the Income Tax Act.
• The Value Added Tax Act, Cap. 148 R.E. 2023. It zero-rates exports and, in a proviso to section 72(3), denies input tax credit on raw minerals. TRA publishes the Revised Edition 2023 of the VAT Act.
• The Local Government Finance Act, Cap. 290. It lets councils charge service levy on turnover.

The Finance Acts change these rates every 1 July. The Finance Act 2024 and the Finance Act 2025 both moved figures in this guide. TRA lists every current Act, including the Finance Act 2026, on its laws page.

Older guides cite the mining sections as 65A to 65J, the Revised Edition 2019 numbers. Use sections 66 to 75 of the Revised Edition 2023 in any filing.

What changed on 1 July 2026?

The Finance Act 2026, assented on 30 June 2026, left the rates in this guide unchanged. It added construction-stage reliefs for mining projects in which the Government has an ownership interest:

• Income tax. Section 21 adds section 10(3)(b)(iii): a Cabinet-approved exemption under a framework agreement, which ends when production starts.
• VAT. Section 92 amends section 6(3)(j) of the VAT Act for goods and services used solely for construction under such an agreement.
• Excise. Section 9 adds a Ministerial remission by Gazette order, excluding petroleum products.

Section 55 also adds section 149A to the Mining Act. It sends 10 percent of royalties and fees to a new Mineral Survey Fund, without raising the rate paid.

Who should read this

This guide is for holders of a mining licence or special mining licence, finance teams building a mine model, investors and lenders, contractors who supply technical services to mines, and buyers and sellers of mineral rights.

Primary mining licence holders pay royalty too, and their buyers withhold a final tax. Our mining licence guide explains which licence you hold.

What does a Mainland mining company pay?

The table lists each charge for a typical gold producer. Rates come from the Zatra fee register, which ties each line to its legal basis.

How are royalty and the inspection fee charged?

Royalty is charged on gross value at the rates in section 111(1) of the Mining Act R.E. 2023, formerly section 87. Gold, copper, silver and other metallic minerals pay 6 percent. Uranium pays 5 percent and most industrial minerals pay 3 percent (F0624).

The inspection fee is 1 percent of gross value, charged before minerals are cleared for export or domestic use (F0625). The HIV Response Levy of 0.1 percent was added as section 113A by section 78 of the Finance Act 2025, from 1 July 2025 (F0626).

Gold sold to the Bank of Tanzania carries royalty at 4 percent and no inspection fee (F0627). The Bank of Tanzania public notice of 1 October 2024 sets out the purchase terms. Our guide to selling gold to the Bank of Tanzania explains the 20 percent set-aside behind that concession.

The export link is covered in our mineral export permit guide.

How is corporate income tax computed for a mine?

A resident mining company pays income tax at 30 percent of taxable income (F0196). Three mining rules change how that income is measured.

Each mineral right is ring-fenced

The Finance Act 2016 inserted a mining division into the Income Tax Act. Its rule on separate mining operations reads: "each mineral right shall constitute a separate mining operation". That text appears in the Finance Act 2016 bill as published in the Gazette of 17 June 2016. In the Revised Edition 2023 the rule is section 68.

Income and costs are therefore computed licence by licence. PwC's Tanzania tax summary, last reviewed on 9 September 2026, states the same rule: losses from one licence area offset only profits from that area.

Mining losses can shelter only 60 percent of income

Section 71 of the Income Tax Act R.E. 2023 governs losses from mining operations. Paragraph (c) of subsection (1) lets a loss reduce the income of the same operation, but not below a floor. The 2016 text set that floor at 30 percent of income before losses.

Section 51 of the Finance Act 2025 replaced "thirty" with "forty" in section 71(1)(c), from 1 July 2025. A mine with brought-forward losses therefore pays tax on at least 40 percent of its income each year. Losses can shelter at most 60 percent, and the unused balance carries forward.

Auditax International's note on the Finance Act 2025 for extractives, dated 10 July 2025, reads the change the same way. Section 52 made the same change to section 75(4) for processing, smelting and refining.

The general loss rule in section 19(2) moved in parallel. Section 36 of the Finance Act 2024 replaced "thirty" with "forty" there from 1 July 2024. Our guide to tax losses and ring-fencing covers section 19 for other businesses.

Does alternative minimum tax apply to a loss-making mine?

Alternative minimum tax is 1 percent of turnover (F0198). Section 60(d)(ii) of the Finance Act 2025 raised it from 0.5 percent from 1 July 2025.

The trigger is in section 4(1)(a) of the Income Tax Act. It applies to a corporation with "a perpetual unrelieved loss determined under section 19" for the year and the two previous years. Section 4(8) excludes agricultural business, health and education. It does not mention mining.

Mining losses are computed under section 71, not section 19. The RSM Tanzania Tax Guide 2025/26 states that mining operations are exempt from the minimum tax. We have not found TRA guidance confirming that reading. Treat it as open: ask TRA, or seek a minimum tax review before you file.

What withholding taxes does a mining company handle?

Three withholding lines matter most for a mine.

• Technical and management services. Fees for technical or management services to mining carry withholding at 10 percent for residents and 15 percent for non-residents (F0213). Section 60(e)(i) of the Finance Act 2025 raised the resident rate from 5 percent.
• Purchases from small miners. A buyer of minerals from primary mining licence holders and artisanal miners withholds 2 percent as a final tax (F0629, F0224).
• Ordinary payments. Rent, interest, dividends and other service fees follow the general schedule. See our withholding tax guide.

The Finance Act 2025 also amended section 54 of the Tax Administration Act. As summarised by Auditax, extractive entities must disclose each subcontractor, the contract value, the work and its duration within 30 days of the work starting.

How is a transfer of a mineral right taxed?

A mineral right is an asset in its own right. The 2016 text, now section 73, says mineral rights are separate from any other interest in the land. A right realised before production starts is treated as an investment asset.

Gains on realising mineral or petroleum rights attract a single instalment of 30 percent of the gain under section 115(1)(c) (F0237). RSM's 2025/26 guide reports the same rate and notes that a pre-production gain is computed apart from business income.

Three further charges follow most deals:

• the Mining Commission's fee for transferring a mineral right other than a PML, USD 3,000 (NEW-06-16);
• stamp duty at 1 percent on a transfer of shares (F0264), or conveyance duty on other instruments (F0262);
• tax on an indirect transfer where shares in a company holding the right change hands, under the change of control rules.

Commission consent comes first. Our guides to mining licence transfers and capital gains tax on shares cover the sequence.

How does VAT work for a mining company?

The standard rate is 18 percent (F0239). Exports of goods are zero-rated under section 55(1) of the VAT Act R.E. 2023 (F0241). Gold sold to the Bank of Tanzania is zero-rated as well (F0627).

The difficulty is input tax. Section 72(3) of the VAT Act lists blocked inputs, and its proviso reads: "in the case of raw minerals, input tax credit shall not be allowed with effect from the 20th day of July, 2017." A miner exporting raw minerals can therefore face VAT on its inputs that it cannot recover.

The scope of "raw minerals" decides how much this costs. The Natural Resource Governance Institute wrote on 24 June 2020 that the Government had read the term as anything not refined in Tanzania. It also said the Finance Act 2020 reintroduced VAT refunds for mineral exports. We did not locate the definition in the Revised Edition text we read, so confirm with TRA how your product is classed.

Our guides to input VAT claims and zero-rated exports cover the refund process.

What are the service levy and the Government's free carried interest?

Service levy

Councils charge service levy on the turnover of corporate entities in their area. The rate is 0.25 percent of turnover net of VAT and excise duty from 1 July 2025 (F0544, F0630). Before that date the Local Government Finance Act allowed up to 0.3 percent, and the Finance Act 2025 cut it.

Some older material describes a 0.3 percent service levy for mining companies under the Mining Act. We did not find a service levy provision in the Mining Act text we read. On our reading the levy is the general council charge, now 0.25 percent. Our service levy guide explains how councils assess it.

Free carried interest

Section 10 of the Mining Act, in the TanzLII 2019 consolidation, gives the Government "not less than sixteen percent non-dilutable free carried interest shares" in a company holding a mining licence or special mining licence. The same section lets the Government acquire up to 50 percent of the shares, in line with the tax expenditure the company has received.

The rule came in with the 2017 natural wealth reforms, which also raised metallic royalty to 6 percent. Addleshaw Goddard's September 2017 briefing summarised those changes. Clyde & Co, writing on 26 February 2024, names the Mining (State Participation) Regulations, GN 574 of 2022, as the detailed rules, with the Treasury Registrar holding the shares.

The free carry is not a tax, but model it with the taxes. Local content rules add further ownership checks, covered in our local content guide, and community spending duties sit in our mining CSR guide.

Which payroll and stamp duty charges apply?

The employer runs PAYE at the resident bands (F0176 to F0180) and pays:

• Skills and Development Levy of 3.5 percent of gross emoluments, for employers with 10 or more employees, by the 7th of the following month (F0276);
• Workers Compensation Fund contributions of 0.5 percent of gross earnings (F0281);
• NSSF contributions of 20 percent of wages, with the employee share not above 10 percent (F0279).

Stamp duty falls on instruments, not on production. The common mining instruments are share transfers at 1 percent (F0264), leases at 1 percent of annual rent (F0478) and conveyances (F0262). Unstamped instruments cause trouble in evidence. See our stamp duty guide and SDL guide.

What applies in Zanzibar?

The Mining Act applies to Tanzania Mainland only. Royalty, the inspection fee, the free carried interest and the Mining Commission's powers do not reach Zanzibar under that Act.

The Citizen reported on 28 November 2024 that Zanzibar had no dedicated mining law and relied on its 2015 environmental law. We could not confirm whether a Zanzibar mining law has passed since. Treat the mineral regime there as unknown and ask the Revolutionary Government's ministry before planning extraction.

Our guide to Zanzibar payroll taxes covers ZRA and ZSSF, and our Zanzibar VAT comparison covers the two VAT systems.

Worked example: a gold company with TZS 50 billion gross value

Kilima Gold Ltd holds one mining licence in Geita. In the year it produces gold with a gross value of TZS 50,000,000,000 and exports all of it. The figures are illustrative and use the register rates.

Charges on gross value

If Kilima sells 20 percent, or TZS 10 billion, to the Bank of Tanzania, royalty on that part falls to 4 percent and the inspection fee to nil (F0627). Royalty becomes TZS 2,800,000,000 and the inspection fee TZS 400,000,000. That saves TZS 300,000,000.

Corporate income tax

Assume taxable income from the licence of TZS 12,000,000,000 before losses. Kilima has TZS 10,000,000,000 of unrelieved losses from the same licence.

Without the cap, the full TZS 10 billion loss would leave TZS 2 billion taxable and tax of TZS 600 million. The cap brings TZS 840 million of tax forward into this year.

Kilima also pays a resident drilling contractor TZS 2,000,000,000 for technical services. It withholds TZS 200,000,000 at 10 percent (F0213) and remits it to TRA. At the non-resident rate of 15 percent it would withhold TZS 300,000,000.

The company's own charges total TZS 5,365,000,000, about 10.7 percent of gross value, before payroll levies, blocked VAT, rent and the Government's 16 percent share.

Who decides disputes, and when do you need an advocate?

Two regulators enforce this stack by different routes.

A TRA objection is not admitted until the deposit is paid, as our TRAB and TRAT appeal guide explains. Representation before the Board, the Tribunal or any court, a seizure of minerals, a prosecution and any formal legal opinion belong with an advocate. Zatra prepares the file and works alongside your advocate.

What to do now

1. Map each licence. List every mineral right as a separate mining operation and keep its income, costs and losses apart.
2. Rebuild the loss forecast. Apply the 40 percent floor from 1 July 2025 to each licence and plan the tax cash flow.
3. Test minimum tax exposure. If any year shows a loss, ask TRA in writing whether alternative minimum tax applies to your mining operation.
4. Check contractor withholding. Confirm that technical service fees are withheld at 10 or 15 percent and that subcontractor disclosures go in within 30 days.
5. Classify your product for VAT. Confirm with TRA whether your output counts as raw minerals before you budget for input tax recovery.
6. Compare the Bank of Tanzania route. Price the royalty and inspection fee saving on gold sold to the Bank against your export plan.
7. Reconcile council and payroll charges. Check the service levy at 0.25 percent and SDL, WCF and NSSF each month.
8. Brief an advocate early. Send any assessment, suspension notice or seizure to an advocate before the time limit starts to run.

Key dates and deadlines

How Zatra helps

Zatra's mining licensing team maps the full charge stack against your licences and export plan. Our tax advisory service models ring-fenced income, loss caps and withholding. Our TRA audit and dispute service prepares objection files with your advocate.

Government fees, royalties and taxes are paid to the Mining Commission, TRA and the council at the official rate against each authority's control number. They are separate from Zatra's professional fee, which we quote in writing before work starts. Zatra does not decide or guarantee any authority's outcome. TRA, the Mining Commission, the councils and the courts decide.

To start, contact Zatra with your licence numbers, last return and production forecast.

Sources and status

Accurate as at 7 November 2026.

• Income Tax Act, Cap. 332 R.E. 2023. TRA, 2023 revision. Accessed 7 Nov 2026.
• Value Added Tax Act, Cap. 148 R.E. 2023. TRA, 2023 revision. Accessed 7 Nov 2026.
• Finance Act, 2026. TRA, assented 30 June 2026. Accessed 7 Nov 2026.
• Finance Act, 2025. TRA, assented 30 June 2025. Accessed 7 Nov 2026.
• Finance Act, 2024. TRA, assented 30 June 2024. Accessed 7 Nov 2026.
• Laws page. TRA, 2026. Accessed 7 Nov 2026.
• Finance Act 2016, Bill Supplement No. 12. Government Gazette, 17 June 2016. Accessed 7 Nov 2026.
• Mining Act, Cap. 123, consolidated to 30 November 2019. TanzLII, 2019. Accessed 7 Nov 2026.
• The Mining Act. Mining Commission, June 2025. Accessed 7 Nov 2026.
• Public notice: Domestic Gold Purchase Program. Bank of Tanzania, 1 October 2024. Accessed 7 Nov 2026.
• Tanzania: Corporate deductions. PwC Worldwide Tax Summaries, reviewed 9 September 2026. Accessed 7 Nov 2026.
• Tanzania Tax Guide 2025/26. RSM Tanzania, 2025. Accessed 7 Nov 2026.
• Tanzania Finance Act, 2025 and implications to the extractive industry. Auditax International, 10 July 2025. Accessed 7 Nov 2026.
• The concept of free carried interest and state participation. Clyde & Co, 26 February 2024. Accessed 7 Nov 2026.
• New mining legislation passed in Tanzania. Addleshaw Goddard, September 2017. Accessed 7 Nov 2026.
• Tanzania strikes a better balance with its mining fiscal regime. Natural Resource Governance Institute, 24 June 2020. Accessed 7 Nov 2026.
• How Zanzibar hopes to promote economic growth with mining law. The Citizen, 28 November 2024. Accessed 7 Nov 2026.
• Zatra government fee register, lines F0196, F0198, F0213, F0224, F0237, F0264, F0276, F0544, F0624 to F0630, NEW-05-04 and NEW-06-16. Zatra Consultants, 2026. Accessed 7 Nov 2026.

Figures to confirm before you act

• Whether TRA applies alternative minimum tax to a mining operation whose losses arise under section 71.
• The section number of the free carried interest provision in the Mining Act R.E. 2023, and the current State Participation Regulations.
• The VAT meaning of "raw minerals" and whether your product can recover input tax.
• The current depreciation class and rate for mining capital expenditure.
• The NEMC environmental fee on minerals produced, and how NEMC collects it.
• The Zanzibar SDL rate: 3 percent from 1 July 2026 under the Zanzibar Finance (Public Revenue Management) Act, 2026, s.20 (F0278); confirm the commencement date with ZRA.
• Whether Zanzibar has enacted a mining law since November 2024.
• Every rate here after the Finance Act each 1 July.

This article is general information based on official sources available at the date of publication. It is not legal, tax or financial advice. Laws and notices change. Verify with the issuing authority or consult Zatra before acting.