Dar Struggles to Win a $206M Tax Case Against Russian Firm



By ADAM IHUCHA

Tanzania faces an uphill battle to push through a legal path in a bid to win a multi-million-dollar tax case against the Russian state uranium firm.

The state demands nearly $206 million in taxes from the JSC Atomredmetzoloto (ARMZ), emanating from Mkunju River Uranium mine, but the mining arm of Russia’s nuclear watchdog, Rosatom disputes the invoice.

As a result, the ARMZ uranium holding through FB Attorneys had filed a case before the Tax Appeals Tribunal of Tanzania, challenging the state’s multi-million-dollar tax claims.

The FB Attorneys counsel, Gaudiosus Ishengoma, confirmed that ARMZ had unwaveringly challenged the Tanzania’s tax demands in the Tax Tribunal.

Energy and Mineral Minister, Prof Sospeter Muhongo told the Parliament that the $205.80 million tax originated from Mkunju River Uranium mining.

Tanzanian law stipulates that any foreign firm operating in the country should pay capital gains tax, when exchange hands to a third party.

The law was enacted in 2011 to seal loopholes in a tax holiday incentive package, which provides foreign firms to operate tax-free for their first five years term.

Taking advantage of the law, unscrupulous companies have been shifting proprietorship after the tax holiday elapses in order to continue enjoying tax-free.

Mantra Tanzania Ltd, the former owner of Mkunju uranium mine, in December 2010 ceded the project operations to ARMZ after the latter purchased the parent company – Mantra Resources of Australia for $1,043.80 million.

Immediately, after the transaction, the state through Tanzania Revenue Authority issued the tax invoice, demanding the ARMZ firm to pay $205.80-million in taxes.

Prof. Muhongo said that  $196-million out of the total sum, is capital gains tax and $9.8-million is stamp duty.

“But the Russian corporation had rejected the tax claims and taken the issue to the Tax Appeals Tribunal” he said.

The sum in question is equivalent to 43 percent of the current Health and social welfare budget of Tsh 753.85billion or $471.250 million.

Analysts say whatever the outcome of the tax battle between the Russian firm and Tanzania could create a bad blood for the two business partners.

In April this year, Tanzania licensed ARMZ uranium holding to build the first uranium mine in Mkuju River in the south of the country.

The license is the first to be granted by Tanzania under its new mining legislation.

ARMZ chairperson Vadim Jivov says acquisition of the special mining licence was a breakthrough and a direct result of a two-year painstaking effort at all levels.

Resources of Mkuju River project are projected at 36 000 tonnes of uranium, with 10 000 tonnes of this amount in the inferred category.

The average grade is 0.024 percent to 0.025 percent of uranium.

Anticipates to produce 14 000 tonnes of uranium each year, ARMZ would bring in $448 million investment capital and expects to create 1,600 jobs.

Preliminary projections show that Tanzania will rake in $249-million in royalties a year.

The project has also been given the go-ahead by the World Heritage Committee because Mkuju was expunged from the Selous Game Reserve, which is a World Heritage Site.

The project will affect about 0.69 percent of the game reserve.

Senior Geologist Dr. Dalaly Peter Kafumu says that if all goes well and indeed ARMZ produces 14 000 tonnes of uranium, Tanzania would rank second world’s biggest uranium producer, surpassing Canada.

At the moment Kazakhstan is a leading uranium producer in the world, having produced 19,451 tonnes in 2011 and commanding 36 percent of the world's total uranium production, according to the World Nuclear Association.

Kazakhstan is trailed by Canada, which produced 9,145 tonnes or 17 percent of the total production.

Dr Kafumu, however, warned that lack of technology and funds to harness the element for domestic energy use, may deny Tanzania an opportunity to sale its uranium ore on the international market.

However, an environmental lawyer, Dr. Eliamani Laltaika, raised a red flag against the project, which could lead to the creation of 60 million tons of radioactive and poisonous waste by the mine during its 10-year lifespan.

“Mkunju Uranium mining is inherently hazardous, dangerous, and harmful. Its negative effect to a poor country like Tanzania outweigh any profit that can ever be accrued” Dr Laltaika told this reporter.

Green activists say the radioactive wastes pose a serious threat to Selous Game Reserve, which is home to the world’s largest elephant population and other wildlife. 

No proven methods exist to keep the radioactive and toxic slush and liquids from seeping into surface waters, aquifers or spreading with the dry season wind into the Reserve.

It remains completely unclear how the company or the Government of Tanzania will guarantee that the impact of millions of tons of radioactive and toxic waste will be “limited".

Tanzania, East Africa’s second-largest economy, is gambling on revenue from the mining sector as a key financier of its medium- term economic growth plan, which runs to 2016. 

The country’s targeting an average growth rate of 8 percent a year.

National Bureau of Statistics shows the mining sector contributes a paltry 2.8 percent to the country’s gross domestic product. Earnings from the sector have increased steadily from $1.7-billion in 2005 to $3.6-billion in 2011.

In 2010, Tanzania enacted a new mining law that seeks to ensure the natural resource rich country reaps maximum benefits from the sector. 

The new law increased royalties to five percent for uranium, diamonds, and uncut gemstones, four percent for gold and all metallic minerals, three percent for industrial and other minerals, and one percent for gems.

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