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Mining Royalty – Tax Court Judgment
Tharisa plc
(Incorporated in the Republic of Cyprus with limited liability)
(Registration number HE223412)
JSE share code: THA
LSE share code: THS
A2X share code: THA
ISIN: CY0103562118
LEI: 213800WW4YWMVVZIJM90
('Tharisa' or the 'Company')
MINING ROYALTY – TAX COURT JUDGMENT
Shareholders are advised that the Tax Court of the Republic of South Africa has delivered a favourable
judgment in the matter between Tharisa Minerals Proprietary Limited ("Tharisa Minerals" ), a wholly-
owned subsidiary of Tharisa, and the Commissioner for the South African Revenue Service ("SARS")
relating to the determination of Mining Royalties in terms of the Mineral and Petroleum Resources
Royalty Act, 2008 ("the Royalty Act").
The Court set aside SARS's assessments for the 2015 and 2017 years of assessment and directed SARS
to redetermine the methodology used to calculate Tharisa Minerals' gross sales and earnings before
interest and tax ("EBIT"), taking into account the "operational realities on recoveries and related
costs" – specifically, the grade recovery curve applicable to Tharisa Minerals.
The judgment is applicable to the years 2015 and all subsequent years of assessment. SARS retains
the right to appeal the judgement. A redacted version of the judgment was published on SARS's
website on or about 3 October 2025.
The dispute related exclusively to the calculation of gross sales and EBIT values for platinum group
metals ("PGMs"), and not to chrome concentrate. SARS had increased the gross sales value of PGM
sales to the minimum specified condition of 150 parts per million, by adjusting the average PGM grade
on a linear basis. Tharisa Minerals objected and appealed against this approach, contesting both the
grossing-up methodology and SARS' determination of incremental cash costs required to beneficiate
the concentrate to the specified standard.
As at 30 September 2024, Tharisa Minerals had conservatively raised a provision of US$56.8 million
for the disputed Mining Royalty. Tharisa Minerals is now recalculating the Mining Royalty liability, as
well as the impact on cost of sales and income tax, applying the principles set out in the judgment
retrospectively from the 2015 year of assessment to date. While the impact is expected to be
materially favourable to earnings per share, the detailed recalculation is in progress. A further
announcement providing earnings guidance will be released once this process is complete.
Commenting on the judgment, Michael Jones, Chief Financial Officer of Tharisa, said:
"This was a highly technical matter, requiring alignment of complex metallurgical processes with the
provisions of the Royalty Act. The case was argued primarily on principles of law rather than
calculations, which are still being finalised. The judgment now provides certainty for the life of mine in
determining Mining Royalties, taking into account the unique characteristics of our ore body.
Importantly, it confirms that royalties should not be levied on notional or artificial income, which is
especially prejudicial to producers mining lower-grade ore bodies. While the process has been lengthy,
the outcome vindicates Tharisa Minerals' position and highlights the need for more clarity from a
legislative perspective."
Paphos, Cyprus
6 October 2025
JSE Sponsor
Investec Bank Limited
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Investor Relations Contacts:
Ilja Graulich (Head of Investor Relations and Communications)
+27 11 996 3500
+27 83 604 0820
igraulich@tharisa.com
Broker Contacts:
Peel Hunt LLP (UK Joint Broker)
Ross Allister / Georgia Langoulant
+44 207 418 8900
BMO Capital Markets Limited (UK Joint Broker)
Thomas Rider / Nick Macann
+44 207 236 1010
Berenberg (UK Joint Broker)
Matthew Armitt / Jennifer Lee / Detlir Elezi
+44 203 207 7800
About Tharisa
Tharisa is an integrated resource group critical to the energy transition and decarbonisation of economies. It
incorporates exploration, mining, processing and the beneficiation, marketing, sales, and logistics of PGMs and
chrome concentrates, using innovation and technology as enablers. Its principal operating asset is the multi-
generational Tharisa Mine, located in the south-western limb of the Bushveld Complex, South Africa. Tharisa is
also developing the Karo Platinum Project, a tier-one PGM asset located on the Great Dyke in Zimbabwe, while
simultaneously focusing on beneficiation in the form of chrome and PGM alloys. Redox One is accelerating the
development of a proprietary iron chromium redox flow long-duration battery utilising the commodities we
mine. Tharisa plc is listed on the Johannesburg Stock Exchange (JSE: THA) and has an Equity Shares (Transition)
Category listing on the London Stock Exchange (LSE: THS).
Date: 06-10-2025 10:15:00
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