Most transactions involving the sale of shares or interests in companies holding mining and petroleum licences in Namibia have not been reported for tax purposes, the Namibia Revenue Agency (NamRA) has revealed.
NamRA Commissioner Sam Shivute said compliance with tax obligations linked to such transactions remains extremely low, with only about 5% of deals declared over the past decade.
According to NamRA data, approximately 250 licence-related transactions have taken place in Namibia during the past ten years, yet the majority were not reported for tax assessment.
“From the data that we are having now, we’re talking about maybe about 250 licences that have been traded over a period of about 10 years, and the compliance rate, as we are saying, is only 5%,” Shivute said.
He made the remarks during a stakeholder engagement session held at NamRA’s head office in Windhoek aimed at clarifying tax obligations related to the sale or transfer of shares in companies that hold mineral and petroleum licences.
Shivute noted that Namibia introduced provisions in 2011 allowing the taxation of gains arising from the disposal of mining interests, while similar provisions covering petroleum licence transactions were implemented in 2015.
He said NamRA has recently strengthened its enforcement capacity through technical cooperation with institutions such as the African Development Bank, the International Monetary Fund and the African Tax Administration Forum.
The enhanced capacity has enabled the agency to identify previously undisclosed transactions, including one deal valued at more than US$100 million.
“We have moved into a stage now where we are strengthening our compliance mechanisms. Because of this capacity, we are able to pick up transactions that were previously not visible, and tax has to be paid on that,” Shivute said.
He urged companies operating in the mining and petroleum sectors to prioritise voluntary compliance as the agency strengthens its audit systems and monitoring of licence-related transactions.
Shivute also reminded taxpayers that Namibia’s tax amnesty programme, introduced in 2017, will expire on 31 October 2026, after which stricter enforcement measures are expected.
“Voluntary compliance will help. People should make proper arrangements before the amnesty comes to an end,” he said.
NamRA maintains a growing database of licence transfers and share disposals dating back to 2011. Shivute noted that tax liabilities arising from such transactions do not prescribe, meaning they can still be pursued by the tax authority.
The stakeholder engagement session brought together representatives from the mining, oil and gas industries, as well as accountants and tax specialists, to clarify reporting requirements and highlight the tax implications of licence-related transactions.
