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Reforming Zambia’s legal and institutional framework to curb illicit financial flows through transfer pricing in its mining sector: a case study of Mopani Copper Mines Plc v The Zambia Revenue Authority (2020) ZMSC 29
Mini Dissertation (LLM (Trade and Investment Law))--University of Pretoria, 2025.
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| Format: | Thesis |
| Language: | English |
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University of Pretoria
2025
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| _version_ | 1867613716844904448 |
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| access_status_str | Open Access |
| author2 | De Gama, Rafia |
| author_browse | De Gama, Rafia |
| author_facet | De Gama, Rafia |
| collection | Thesis |
| dc_rights_str_mv | © 2024 University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria. |
| description | Mini Dissertation (LLM (Trade and Investment Law))--University of Pretoria, 2025. |
| format | Thesis |
| id | oai:repository.up.ac.za:2263/106972 |
| institution | University of Pretoria (South Africa) |
| language | English |
| last_indexed | 2026-06-10T12:40:34.602Z |
| license_str | Other — see source repository |
| provenance_str_mv | Harvested via OAI-PMH from UPSpace — University of Pretoria Institutional Repository |
| publishDate | 2025 |
| publishDateRange | 2025 |
| publishDateSort | 2025 |
| publisher | University of Pretoria |
| publisherStr | University of Pretoria |
| record_format | dspace |
| source_str | UPSpace — University of Pretoria Institutional Repository |
| spelling | oai:repository.up.ac.za:2263/106972 Reforming Zambia’s legal and institutional framework to curb illicit financial flows through transfer pricing in its mining sector: a case study of Mopani Copper Mines Plc v The Zambia Revenue Authority (2020) ZMSC 29 De Gama, Rafia mutanukafaith@gmail.com Mutanuka, Faith UCTD Sustainable Development Goals (SDGs) Mining Zambia Transfer Pricing Illicit financial flows Mini Dissertation (LLM (Trade and Investment Law))--University of Pretoria, 2025. This research explores how Zambia’s legal and institutional framework can be reformed to curb IFFs through transfer pricing using the case of Mopani Copper Mines v The Zambia Revenue Authority as a case study. Zambia, like many other resource rich African countries remains financially constrained due to illicit financial flows. This research explores how illicit financial flows through transfer pricing abuse by multinational companies occur in Zambia’s mining sector while integrating the broader context the Sustainable Development Goal 16.4 ‘to significantly reduce illicit financial and arms flows, strengthen the recovery and return of stolen assets and combat all forms of organised crime’. As one of the first transfer pricing cases won by ZRA in Zambia’s highest court of law, the MCM case serves as a focal point of this study. This case is significant to this study as it highlights important factors that signify the complexity of transfer pricing audits and case determination. The study relies on primary and secondary data to draw conclusions and provide recommendations. It sheds light on the progress made by Zambia in aligning its transfer pricing regulations to international standards and recognises the negative implications of illicit financial flows on the Zambian economy. Key findings of this research include the capacity constraints faced by ZRA in carrying out transfer pricing audits despite having legislation in line with the OECD guidelines and UN practice manual on transfer pricing. In conclusion, the study examines the collaborative approaches required to ensure that transfer pricing as a tool of illicit financial flows is curbed as a way to maximise revenue generation and contribute to the realisation of SDG 16.4. Centre for Human Rights LLM (Trade and Investment Law) Unrestricted Faculty of Laws SDG-16: Peace, justice and strong institutions 2025-11-28T09:50:40Z 2025-11-28T09:50:40Z 2025-12-10 2025-09-30 Mini Dissertation * D2025 http://hdl.handle.net/2263/106972 Disclaimer letter en © 2024 University of Pretoria. All rights reserved. The copyright in this work vests in the University of Pretoria. No part of this work may be reproduced or transmitted in any form or by any means, without the prior written permission of the University of Pretoria. application/pdf University of Pretoria |
| spellingShingle | UCTD Sustainable Development Goals (SDGs) Mining Zambia Transfer Pricing Illicit financial flows Reforming Zambia’s legal and institutional framework to curb illicit financial flows through transfer pricing in its mining sector: a case study of Mopani Copper Mines Plc v The Zambia Revenue Authority (2020) ZMSC 29 |
| title | Reforming Zambia’s legal and institutional framework to curb illicit financial flows through transfer pricing in its mining sector: a case study of Mopani Copper Mines Plc v The Zambia Revenue Authority (2020) ZMSC 29 |
| title_full | Reforming Zambia’s legal and institutional framework to curb illicit financial flows through transfer pricing in its mining sector: a case study of Mopani Copper Mines Plc v The Zambia Revenue Authority (2020) ZMSC 29 |
| title_fullStr | Reforming Zambia’s legal and institutional framework to curb illicit financial flows through transfer pricing in its mining sector: a case study of Mopani Copper Mines Plc v The Zambia Revenue Authority (2020) ZMSC 29 |
| title_full_unstemmed | Reforming Zambia’s legal and institutional framework to curb illicit financial flows through transfer pricing in its mining sector: a case study of Mopani Copper Mines Plc v The Zambia Revenue Authority (2020) ZMSC 29 |
| title_short | Reforming Zambia’s legal and institutional framework to curb illicit financial flows through transfer pricing in its mining sector: a case study of Mopani Copper Mines Plc v The Zambia Revenue Authority (2020) ZMSC 29 |
| title_sort | reforming zambia s legal and institutional framework to curb illicit financial flows through transfer pricing in its mining sector a case study of mopani copper mines plc v the zambia revenue authority 2020 zmsc 29 |
| topic | UCTD Sustainable Development Goals (SDGs) Mining Zambia Transfer Pricing Illicit financial flows |
| url | http://hdl.handle.net/2263/106972 |