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Heightened copper prices and the perceived profiteering of foreign mining investors in the 2000s spurred calls for greater revenue from mineral extraction in Zambia. Following the abrogation of the over-concessionary development agreements (DAs) in 2008 and the concomitant formation of the Mining Taxation Unit in the Large Taxpayer Office, the Zambia Revenue Authority (ZRA) has essentially functioned as an instrument of those resource nationalist demands. Building on the professionalisation of the regulatory body under the Mwanawasa administration, the ZRA became a formidable force in the policing of Zambia’s mining fiscal regime. In comparison to the rest of the country’s bureaucracy then, the ZRA functioned as what some scholars have termed a ‘pocket of effectiveness’ (POE). From 2006 until 2014, under the aegis of a ‘technocratic coalition’ made up of officials at the ZRA and Ministry of Finance, sympathetic politicians, and foreign technical advisers, the revenue authority was able to bolster its capacity to administer mining taxation. It is essential that the ZRA is not merely examined as an administrative institution outside of the political realm. This article’s contribution is that it examines the political factors that shape the ZRA’s emergence, performance and sustainability over time in relation to mining taxation. It demonstrates how the nature of Zambia’s political settlement, the structural power of the foreign mining investors and the weaknesses of other government ministries have encumbered the effectiveness of the ZRA as an instrument of resource nationalism. The article is based on interviews with a wide range of actors, quantitative and qualitative data and unreleased sources.

Asymmetries of Power and Capacity: The Zambia Revenue Authority (ZRA) as an Instrument of Resource Nationalism, 1994–2021