[SMM News] Zimbabwe's Lithium Export Ban Creates Tax and Transfer Pricing Challenges for Multinationals

Published: Sep 7, 2026 18:41

SMM, September 4: Zimbabwe suspended exports of all raw minerals and lithium concentrates with immediate effect in late February 2026, citing alleged malpractices and leakages. The ban on lithium concentrates had previously been expected to take effect only in 2027, while a ban on unprocessed lithium ore was introduced in 2022.

The measures reflect Zimbabwe's aim of limiting raw lithium exports to encourage in country beneficiation and retain more downstream value from lithium production. In the short term, mining companies may find themselves unable to export lithium concentrate under the new rules while also being unable to process the material locally resulting in stalled revenue, higher costs, and disruption to lithium mining operations. Infrastructure constraints, including unreliable electricity supply, compound these challenges, with companies often needing to import skills and technology to establish local processing capacity.

The shift toward local lithium beneficiation is also generating new intercompany transactions covering funding, technical and management services, technology licensing, and the onward sale of beneficiated lithium products each carrying transfer pricing risk. In Zimbabwe, fees for such services may be capped at a percentage of revenue, with further limits on deductibility adding complexity.

Newly established lithium beneficiation entities in the country may post losses tied to startup costs, delays in reaching full production, or disruption from the policy shift itself. Revenue authorities in other jurisdictions may question whether such losses reflect genuine operating conditions or pricing misalignment, placing the onus on companies to document the policy changes, timing delays, and infrastructure constraints behind their results.

As Zimbabwe's lithium beneficiation capacity develops, mining companies will also face scrutiny over the pricing of processed lithium, the allocation of value within corporate groups, and which entities perform key functions, bear risk, and hold critical assets across the lithium value chain.

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