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tax compliance

PROSPECTING LICENSE ZIMBABWE: CLAIMS, TAX AND TRANSFERS

By M&J Consultants • 10 min read
PROSPECTING LICENSE ZIMBABWE: CLAIMS, TAX AND TRANSFERS

A mineral opportunity can look settled on a map and still fail at the Ministry counter. The buyer may have a signed sale agreement, the seller may point to a visible peg, and yet the title may remain unregistered or carry an exposure that prevents transfer.

A prospecting license Zimbabwe application is the starting point for prospecting and pegging. It does not authorise mining. Investors, small scale gold mining operators and mining companies in Zimbabwe need to separate prospecting rights, registered claim rights, environmental approvals and tax obligations before they commit capital.

As of September 2026, the governing law remains the Mines and Minerals Act [Chapter 21:05]. The Mines and Minerals Bill, 2025 was gazetted on 25 June 2025, but it remains a Bill and received an adverse Parliamentary Legal Committee report. We therefore advise clients against planning a transaction on the assumption that Chapter 21:09 already applies.

Start with the right mining title

Zimbabwe uses different steps for finding a mineral occurrence, securing a mining location and transferring an existing title. A prospector’s licence is not a mining licence in the commercial sense many investors expect.

Step 1: Obtain a prospecting licence

A Zimbabwe permanent resident, or that person’s duly appointed agent, obtains a prospecting licence from the relevant Ministry of Mines and Mining Development provincial office. The applicant provides a name, permanent postal address and any further information the Mining Commissioner or Provincial Mining Director requires.

The Ministry’s 2026 guidance says applicants need a national ID or company documents. The licence remains valid for two years and gives prospecting and pegging rights within the relevant province. The province matters because the licence does not create a national right to prospect wherever a geological target appears.

The Ministry guidance refers to a gazetted fee but does not state a current amount. Do not rely on informal figures for how much a prospecting licence in Zimbabwe costs. Confirm the applicable gazetted fee with the provincial office before lodging, then retain proof of payment with the application record.

For a company applicant, establish authority before anyone submits documents. The Zimbabwe Mining Cadastre Portal’s MCP01 access form requires identification, incorporation documents, authority, CR6 and CR14 for company applicants. This document set helps the Ministry identify both the entity and the person acting for it.

Step 2: Use the Zimbabwe Mining Cadastre Portal, then verify at the Ministry

Register and transact through the Zimbabwe Mining Cadastre Portal. It is a useful first check for mining claims Zimbabwe, but the portal states that its data remains provisional while Ministry data cleaning continues.

That qualification deserves attention. A clear-looking area on the portal is not a legal opinion that the ground is open, free from dispute or transferable. Verify the title position with the Ministry before paying a deposit, mobilising equipment or announcing an acquisition.

From 1 July 2025, new, pending and renewing titles must use UTM Arc 1950, Clarke 1880 Spheroid coordinates captured by registered mine surveyors. A coordinate error can undermine an otherwise sound application, which is why we treat the survey instruction as an early workstream rather than a filing detail.

Step 3: Peg and register the claim after discovery

After discovery, appoint an approved prospector or agent to peg the claim. The process requires prospecting, discovery and registration notices, followed by an application to the Provincial Mining Director.

The application package includes the prospecting licence, notices, landowner notification and a triplicate 1:25,000 map. Registration follows when the procedures are satisfied and the gazetted fee is paid. The map requirement is not administrative decoration. It gives the Ministry a defined area against which it can assess the location.

Mining also remains subject to obligations such as environmental impact assessment approval. A frequent mistake is to treat pegging as authority to begin extraction. It is not. If your immediate plan is production rather than exploration, budget and sequence environmental work before equipment reaches site.

Two practical title decisions investors face

The difference between a promising target and a secure mining asset often appears in the paperwork, not the geology.

Illustrative example: a new gold prospect in Matabeleland

Take a Zimbabwean investor who identifies a gold occurrence in Matabeleland and intends to fund initial work with US$80,000. The investor obtains a prospecting licence, sees an apparently available area on the Zimbabwe Mining Cadastre Portal and arranges a drill contractor before checking the Ministry record.

The better sequence is to verify the area at the Ministry, appoint an approved prospector or agent, complete the notices and landowner notification, and prepare the required triplicate 1:25,000 map. The investor should also instruct a registered mine surveyor to use the post-1 July 2025 coordinate standard. Spending a modest part of an US$80,000 exploration budget on title verification can protect the entire programme from a location or registration failure.

What would we do differently from the start? We would not sign a non-refundable drilling commitment until the title route, survey basis and environmental approval path are documented. A prospecting licence permits prospecting and pegging within the province for two years, but it does not remove the registration and EIA steps.

Illustrative example: buying an existing mining claim

Consider a buyer agreeing to acquire a registered mining location for US$500,000. The seller provides a title document and a sale agreement, and the buyer assumes ownership moves when the money changes hands.

It does not. The seller must notify the Mining Commissioner within 60 days of a sale or alienation, and the transfer remains invalid until registration. The application requires the existing title, prescribed transferor and transferee certificates, transaction agreements, and powers of attorney where they apply.

The buyer also pays transfer duty at US$1 for every US$100, or part of US$100, of consideration. On US$500,000, that produces US$5,000 in transfer duty. The duty falls due within six months, with 12% annual interest on late payment unless an extension applies, so the buyer should place the due date in the closing calendar rather than leave it to post-deal administration.

Before closing, the buyer should check for arrears, attachment or forfeiture exposure because these can block registration. A private agreement may establish commercial obligations between the parties, but it does not replace the statutory registration process.

Special Capital Gains Tax on mining title transfers

Since 1 January 2024, Special Capital Gains Tax has applied to direct and indirect mining-title transfers. The rule reaches beyond a deed or claim sale. It also covers shares, stakes, beneficial interests and transfers to nominees.

This scope changes transaction planning for mining companies in Zimbabwe. An investor cannot assume that a share sale sits outside mining-title tax simply because the claim remains registered in the company’s name.

Calculate the tax exposure before signing

The transferee files through TaRMS, submits a sworn affidavit and pays ZIMRA. The statutory rate is 20% of the transaction value, reduced to 5% where the required mining-law approval is proved.

Take an illustrative US$1 million indirect transfer of a company holding a mining title. At 20%, Special Capital Gains Tax is US$200,000. If the parties can prove the required mining-law approval, the rate may reduce to 5%, or US$50,000, which creates a US$150,000 difference in the transaction model.

The tax and the approval evidence need attention before price, escrow and closing conditions are finalised. Do not confuse this tax with buyer-paid transfer duty, or with seller-side normal Capital Gains Tax. They arise from different rules and can affect different parties.

ZIMRA guidance dated 25 September 2025 says that post-1 January 2024 Special CGT becomes due 30 days after assessment. Section 30B refers instead to 30 days after conclusion of the transaction. This difference can affect a material cash-flow date, so obtain written ZIMRA confirmation before closing rather than choosing the more convenient interpretation.

A step-by-step due diligence checklist

1. Identify the transaction you are actually completing

Ask whether the deal transfers a registered mining location, an interest in a claim-holding company, a beneficial interest or a nominee interest. Special Capital Gains Tax can apply to each of these forms from 1 January 2024.

If you are acquiring only exploration potential and have not made a discovery, do not present a prospecting licence as a mining asset. It gives prospecting and pegging rights, not authority to mine.

2. Confirm the title at the source

Use the Zimbabwe Mining Cadastre Portal as an initial screen, then verify the record with the Ministry of Mines and Mining Development. The portal’s provisional-data notice means a screen capture should never be the sole basis for a board approval.

Request and review the existing title where a transfer is proposed. Check whether arrears, attachment or forfeiture issues could prevent registration.

3. Match the documents to the title stage

For a new claim, retain the prospecting licence, notices, landowner notification and triplicate 1:25,000 map. For a transfer, assemble the existing title, transferor and transferee certificates, transaction agreements and any required powers of attorney.

For company applicants using MCP01, prepare incorporation documents, authority, CR6 and CR14. We see delays when a company treats authority documents as an afterthought and sends an agent without a clear mandate.

4. Set tax and regulatory dates before completion

Place the 60-day notification requirement to the Mining Commissioner in the transaction timetable. Place the six-month transfer-duty deadline there as well, because late payment attracts 12% annual interest unless extended.

Model Special Capital Gains Tax at 20% of transaction value, then assess whether evidence supports the 5% rate. Seek written ZIMRA clarification on the payment trigger where the assessment-date and transaction-date guidance could produce different deadlines.

5. Do not omit environmental approval

Registration of a claim does not complete the operating permission set. Include EIA approval in the project plan before mining begins, particularly where lenders or investors require a defined path from title to production.

M&J’s tax compliance and business advisory work can help enterprises organise the title, corporate and tax records that a transaction requires. For cross-border investors, company registration records and authority documents should align with the mining-title file from the outset.

Frequently Asked Questions

What is a prospecting licence in Zimbabwe?

A prospecting licence gives a Zimbabwe permanent resident, or that person’s duly appointed agent, the right to prospect and peg within the relevant province. Ministry guidance says it is valid for two years. It does not by itself authorise mining.

How do I get a mining claim in Zimbabwe?

After discovery, appoint an approved prospector or agent to peg the claim, post the required prospecting, discovery and registration notices, and apply to the Provincial Mining Director. The application requires the prospecting licence, notices, landowner notification and a triplicate 1:25,000 map, with registration subject to the prescribed process and gazetted fee.

How much is a prospecting licence in Zimbabwe?

The Ministry’s 2026 guidance confirms that a gazetted fee applies but does not state the current monetary amount. Confirm the fee with the relevant Ministry provincial office before filing. We would not advise budgeting from an unofficial online figure.

Who pays Special Capital Gains Tax on a mining-title transfer?

The transferee files through TaRMS, submits a sworn affidavit and pays ZIMRA. Since 1 January 2024, the tax can apply to direct title transfers and indirect transfers through shares, stakes, beneficial interests or nominees.

A mining title can support serious enterprise growth, but only when the registry records, transaction papers and tax position tell the same story. Speak With Our Team before you commit capital to a prospecting licence, claim acquisition or mining-title transfer.

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