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WINDHOEK – The Namibia Revenue Agency (NamRA) has sounded a stern warning to the mining and petroleum sectors, revealing a systemic failure to declare high-value asset transfers for taxation. During a high-stakes stakeholder engagement session this week, NamRA Commissioner Sam Shivute disclosed that only 5% of the approximately 250 license-related transactions recorded over the last decade were voluntarily reported to the tax authority. The discovery follows a period of enhanced technical cooperation between NamRA and international bodies like the International Monetary Fund and the African Development Bank, which has bolstered the agency’s ability to “see” offshore deals previously hidden from local tax rolls.
This regulatory crackdown targets the sale of shares and interests in companies holding Namibian mineral and petroleum rights transactions that have historically bypassed the national treasury. While provisions to tax these gains were introduced for mining in 2011 and petroleum in 2015, the agency’s new data-driven approach has already flagged one undisclosed transaction exceeding US$100 million. NamRA officials clarified that even transactions concluded abroad between two foreign entities are subject to Namibian law if they involve a domestic asset, emphasizing that these liabilities do not prescribe and can be pursued indefinitely.
“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%,” Commissioner Sam Shivute stated at the agency’s headquarters. He urged industry players to regularize their affairs immediately, noting that NamRA’s capacity to identify previously invisible transactions has fundamentally changed the compliance landscape. “We have moved into a stage now where we are strengthening our compliance mechanisms… tax has to be paid on that,” Shivute added.
The timing of this enforcement surge is critical, as Namibia’s long-standing tax amnesty program is set to expire on October 31, 2026. The program, which offers a 100% write-off of interest and penalties for taxpayers who settle their capital debts, is being framed as the final “olive branch” before the agency pivots to stricter, non-discretionary enforcement measures. Industry representatives, including the Chamber of Mines, have raised concerns that taxing the full transaction value rather than just profit could deter exploration investment, yet NamRA remains firm on the existing legislative framework.
For the Namibian treasury, reclaiming these “lost” revenues is essential as the country positions itself as a global hub for green hydrogen and oil and gas. By building a comprehensive database of license transfers and share disposals dating back to 2011, NamRA is sending a clear signal that the era of tax-free offshore flips of Namibian resources is coming to a close. Accountants and legal specialists in the extractive space are now being urged to prioritize the voluntary disclosure of past deals to avoid the impending post-amnesty penalties.
