Namibia’s tax authority has raised concerns about the limited disclosure of transactions involving mining and petroleum licences, warning that a significant number of deals concluded over the past decade have not been declared for taxation.
According to the Namibia Revenue Agency (NamRA), only about five percent of transactions involving the transfer of shares or interests in companies holding mineral and petroleum licences have been reported for tax assessment during the last ten years. The agency estimates that roughly 250 such transactions occurred during this period.
Speaking at a stakeholder engagement session at NamRA’s headquarters in Windhoek, Commissioner Sam Shivute said the low level of compliance has prompted the agency to intensify oversight of licence related transactions in the extractive sector. The engagement brought together representatives from the mining industry, the oil and gas sector, accounting professionals and tax specialists to clarify reporting obligations and the tax implications of these deals.
Namibia introduced legislative provisions in 2011 allowing the taxation of gains arising from the disposal of mining interests, reflecting a broader effort by resource rich African countries to ensure that the transfer of extractive assets generates fair fiscal returns for host states. Comparable provisions covering petroleum licence transactions were introduced in 2015, extending the tax framework to the rapidly developing hydrocarbons sector. Academic analyses of Namibia’s extractive governance note that these reforms were designed to capture revenue from indirect transfers of resource assets that may occur through offshore share sales rather than direct licence transfers.
Shivute indicated that NamRA’s analysis of available data suggests that the majority of transactions involving the sale or transfer of interests in licence holding entities have not been declared for tax purposes. The agency has recently strengthened its enforcement capacity through technical cooperation with institutions including the African Development Bank, the International Monetary Fund and the African Tax Administration Forum. These partnerships have focused on improving audit capabilities and developing tools to identify complex corporate structures that may obscure the true value of resource related transactions.
He said these efforts have already enabled the authority to detect previously undisclosed transactions, including one deal valued at more than 100 million United States dollars. According to Shivute, improved analytical capacity has made it possible to trace ownership changes in companies holding exploration or production rights even when the transfer occurs through the sale of shares rather than a direct licence assignment.
“Because of this capacity we are able to identify transactions that were previously not visible, and tax has to be paid on that,” he said.
NamRA has urged companies operating in Namibia’s extractive industries to prioritise voluntary compliance as the agency expands monitoring and audit processes linked to licence related transactions. The authority maintains a growing internal database tracking licence transfers and share disposals dating back to 2011.
Shivute also reminded taxpayers that Namibia’s tax amnesty programme, introduced in 2017 to encourage voluntary disclosure and settlement of outstanding liabilities, will expire on 31 October 2026. Authorities have indicated that enforcement measures may intensify once the programme concludes.
Under Namibia’s fiscal framework, income derived from business activities within the country is subject to taxation, including gains arising from the disposal of mining and petroleum interests. Analysts have long noted that indirect transfers of extractive assets through share sales represent a complex regulatory challenge across Africa’s resource economies, particularly where multinational corporate structures allow transactions to take place outside the jurisdiction where the underlying resource is located.
Research on the governance of extractive industries in Namibia highlights the importance of transparent reporting and effective tax administration in ensuring that mineral wealth contributes to public revenue and development outcomes. As countries across the continent expand exploration and production in mining, oil and gas, tax authorities are increasingly investing in specialised capacity to track cross border transactions and address revenue leakages associated with resource asset transfers.
Further information about Namibia’s extractive sector governance and fiscal policy can be found through the Institute for Public Policy Research analysis of Namibia’s extractive sector transparency, while details on the country’s tax administration framework are available from the Namibia Revenue Agency.
For many African economies, the strengthening of domestic tax institutions has become central to debates about resource governance and economic sovereignty. Namibia’s current review of compliance in the mining and petroleum sectors reflects wider continental discussions about how states can ensure that natural resource transactions contribute equitably to national development while maintaining a stable investment environment.
