Principles of taxation for mining operations in Uganda

This report was originally published on odi.org on 27 November 2025 here, and is reproduced with kind permission.

Uganda is reforming its mining fiscal framework to improve revenue mobilisation, equity and predictability. This joint TaxDev and Ugandan Ministry of Finance review identifies key gaps in the current regime, including unclear ring-fencing rules, loopholes in the transfer pricing regulations, gaps in asset disposal taxation, and the absence of guidance for joint mineral rights holders. It also highlights inconsistencies between the Income Tax Act and the Mines and Minerals Act that create uncertainty for both government and investors.

Drawing on regional experience from countries such as Sierra Leone, Liberia, Mozambique and Zambia, the paper sets out practical options to align Uganda’s mining tax regime with international good practice and support effective, long-term sector governance.

The analysis is intended for policymakers and revenue administrators in Uganda, as well as development partners, tax professionals and regional authorities interested in extractives tax reform.