On 29 December 2025, the Finance Act (No. 7) of 2025 was gazetted. The Act introduces a range of significant fiscal and regulatory amendments, several of which have direct and far-reaching implications for Zimbabwe’s mining sector. These amendments take effect from 1 January 2026.

Collectively, the changes reflect a deliberate policy shift towards enhanced revenue mobilisation from the extractive industry, strengthened oversight of mineral export pricing, and the promotion of local value addition and beneficiation particularly in relation to strategic minerals.

Set out below are some of the key mining-specific provisions and developments arising from the Finance Act (No. 7) of 2025, with particular relevance to the 2026 fiscal year.

1.0 Amendment of Section 22P in Cap. 23:04 – Levy on Gross Value of Lithium, Black Granite, Quarry Stones and Dimensional Stones

• Section 10 increases the levy from one per centum (1%) to three per centum (3%) on the gross value of the sale within Zimbabwe or on export of coal, lithium, black granite, quarry stones, and uncut and cut dimensional stone (whether polished or unpolished).

• amends the section by adding coal to the list of minerals subject to the levy. The levy now applies to the gross value of the sale within Zimbabwe or on export of coal, lithium, black granite, quarry stones, and uncut and cut dimensional stones (whether polished or unpolished).
  

2.0 Amendments to the Value Added Tax Act [Chapter 23:12] on VAT Applicable to Export of Certain Unbeneficiated Minerals

2.1 Section 39 – Amendment of Section 12B (Export of Unbeneficiated Lithium)

• Repeals subsection (1) of section 12B and substitutes a new provision.
• VAT is levied notwithstanding section 10(1) as follows:
  • Section 12B(1)(a) – Export of unbeneficiated lithium ore: 10% VAT on the gross fair market value, based on the value of realisable lithium sulphate.
  • Section 12B(1)(b) – Export of unbeneficiated lithium concentrate: 10% VAT on the gross fair market value, based on the value of realisable lithium sulphate.
  • Section 12B(1)(c) – Export of lithium sulphate: 0% VAT on the gross fair market value.

2.2 Section 40 – Amendment of Section 12D (Export of Unbeneficiated Platinum)

• Amends section 12D concerning the export of unbeneficiated platinum.
• Section 12D(2)(a) – Export of unbeneficiated platinum: 10% VAT on the value if the supplier has a plant in Zimbabwe capable of producing platinum group concentrates and is approved by the Minister responsible for finance in consultation with the Minister responsible for mines.

2.3 Section 41 – Amendment of Section 12E (Export of Cut and Polished Dimensional Stones)

• Amends section 12E concerning the export of dimensional stones.
• Section 12E(1)(a) – Export of cut and polished dimensional stones: VAT now applies to cut and polished dimensional stones realised from such exports, replacing the previous reference to uncut dimensional stones.

2.4 Section 42 – New Section 12I (Export of Unbeneficiated Chrome)

• Section 12I(1) – Export of unbeneficiated chrome: 10% VAT on the value of unbeneficiated chrome for export from Zimbabwe.
• Includes chrome ore, fines, crushed/milled/washed ore, and chrome concentrate in pellet or ingot form.
• Export value is deemed to be the higher of market value on a reputable metals exchange or the value on the customs bill of entry.

2.5 Section 42 – New Section 12I (Export of Unbeneficiated Antimony)

• Section 12I(2) – Export of unbeneficiated antimony: 10% VAT on the value of antimony for export from Zimbabwe.
• Export value is deemed to be the higher of market value on a reputable metals exchange or the value on the customs bill of entry.

2.6 Section 12K – Currency of Payment for Export Taxes

VAT and export taxes referred to in sections 12B, 12C, 12D, 12E, 12F, 12I, and 12J shall be paid in United States dollars or equivalent foreign currency at the prevailing international exchange rate at the time of transfer.

3.0 Amendment of Section 23 of the Value Added Tax Act [Chapter 23:12] – VAT Registration of Mining Companies

Section 46 of the Finance Act (No. 7) of 2025

• Section 46 amends section 23 of the Value Added Tax Act [Chapter 23:12] relating to the registration of persons making supplies in the course of trade.
• Firstly, subsection (1) is amended by the insertion of a new paragraph (c), which provides that a mining company approved by the Minister shall qualify for VAT registration at the commencement of any month where the company satisfies the Commissioner that its investment in the establishment of a mineral beneficiation plant will exceed United States dollars one hundred million (US$100 million).
• Secondly, subsection (3) is amended by the repeal and substitution of the proviso thereto. The substituted proviso provides that any person holding a special mining lease under the Mines and Minerals Act who commences development for mining purposes in the year of assessment for income tax purposes beginning on or after 1 January 2020 shall be deemed to qualify for VAT registration with effect from 1 January 2020.

4.0 Amendment of the First Schedule to the Indigenisation and Economic Empowerment Act [Chapter 14:33] – Reserved Mining Activities

Section 67 of the Finance Act (No. 7) of 2025

Section 67 amends the First Schedule (“Reserved/Threshold Sectors”) to the Indigenisation and Economic Empowerment Act [Chapter 14:33] by inserting new items 18, 19 and 20. The amendment designates the following activities as reserved sectors:

Quarry mining, defined as the extraction of rock, stone, sand, gravel or other minerals from the earth’s surface, typically through open pit operations, for construction and industrial use.

Brick moulding, defined as the activity of shaping bricks from prepared clay or earth, either manually or mechanically, prior to drying and firing.

Granite mining, defined as the extraction of granite rock, usually through open pit quarrying, including related activities such as locating granite deposits and removing large blocks or slabs for construction, decorative stonework and industrial applications.

5.0 Amendments to Chapter VII of the Finance Act [Chapter 23:04] – Royalty Rates on Gold Produced by Other Miners

Section 61 of the Finance Act (No. 7) of 2025

• Section 61 amends the Schedule to Chapter VII of the Finance Act [Chapter 23:04], which fixes royalty rates for the purposes of section 36O of the Income Tax Act [Chapter 23:06]. The amendment repeals the existing items relating to gold produced by other miners and substitutes them with a tiered royalty structure based on the international gold price at the time of sale. The applicable royalty rates are:
  • 3% where the gold is sold at a time when its price is US$1,200 per ounce;
  • 5% where the gold is sold at a time when its price is above US$1,200 per ounce but below US$5,000 per ounce; and
  • 10% where the gold is sold at a time when its price is above US$5,000 per ounce.

6.0 Amendment of the Gold Trade Act [Chapter 22:15]

Section 66 of the Finance Act (No. 7) of 2025

Section 66 amends the Gold Trade Act [Chapter 22:15] in several respects.

• Firstly, section 2 is amended by the insertion of new definitions, including the definitions of “authorised dealer”, “authorised gold bar”, and “national gold refinery”. An authorised gold bar is defined as a gold bar of 99.5 per centum purity, produced in prescribed units, shapes and dimensions by the National Gold Refinery and bearing its hallmark.
• Secondly, section 3(1) is repealed and substituted to restate the prohibition against dealing in gold, except where a person falls within specified authorised categories. These include holders of licences or permits, holders or tributors, persons authorised under the Mines and Minerals Act to work alluvial gold deposits, authorised employees or agents, authorised dealers, the national gold refinery, and persons who have lawfully acquired authorised gold bars from an authorised dealer or the national gold refinery. The amendment further permits holders of authorised gold bars, subject to the Exchange Control Act, to deal in such bars, including by sale, exchange, pledge or barter.
• Thirdly, a new section 12A is inserted into Part II of the Act. The new section prohibits the tampering with, alteration, defacing, fabrication, misrepresentation, smelting or changing of the form, weight or purity of authorised gold bars. Contravention of this provision constitutes an offence punishable by a fine not exceeding level fourteen or imprisonment for a period not exceeding fifteen years, or both. The section further provides for the seizure, custody and forfeiture of authorised gold bars or related substances in accordance with section 22E.

7.0 Amendment of Thirty-Fifth Schedule in Income Tax Act Cap. 23:06 – Transfer Pricing for Minerals Exported from Zimbabwe

Section 31 of the Finance Act (No. 7) of 2025

Section 31 amends the Thirty-Fifth Schedule (“Transfer Pricing”) of the Income Tax Act [Chapter 23:06] by inserting a new paragraph (f) under paragraph 4(5). This establishes that, in respect of minerals exported from Zimbabwe, the Quoted Price Method shall be applied, adopting the reference price prevailing at the active market. The reference price may be determined using:

• the monthly average London Metal Exchange (LME) cash price;
• the monthly average Fastmarkets Metal Bulletin cash price, if not quoted on the LME;
• the monthly average Shanghai Metals Market cash price, if not quoted on the LME or Fastmarkets; or
• any other approved metal exchange price to the extent other prices are unavailable, less any discounts for proof, low quality, or grade.

8.0 Amendment of Section 2 of the Minerals Marketing Corporation of Zimbabwe Act [Chapter 21:04] – Definition of “Mineral”

Section 60 of the Finance Act (No. 7) of 2025

• Section 60 amends section 2 of the Minerals Marketing Corporation of Zimbabwe Act [Chapter 21:04] by repealing the existing definition of “mineral” and substituting it with a new definition. The amended definition defines a mineral as any naturally occurring solid material, aggregate, or substance extracted from the earth’s crust through mining or quarrying operations, which has not undergone any chemical transformation, smelting, or pyrometallurgical processing.