MINING TAXATION IN THE AGE OF ESG AND PILLAR TWO: COMPARATIVE PERSPECTIVES FROM ROMANIA, SOUTH AFRICA AND GLOBAL JURISDICTIONS
MINING TAXATION IN THE AGE OF ESG AND PILLAR TWO: COMPARATIVE PERSPECTIVES FROM ROMANIA, SOUTH AFRICA AND GLOBAL JURISDICTIONS

Summary/Abstract: This paper examines mining taxation at the intersection of company law, fiscal sovereignty, and environmental, social and governance (ESG) imperatives in the era of the OECD/G20 Pillar Two global minimum tax. Using Romania and South Africa as primary case studies and situating them within a comparative frame that includes Canada, Zambia and Australia, the paper analyses how supranational harmonisation and resource nationalism shape fiscal regimes, corporate governance, and investment incentives in the extractive sector. It argues that mining taxation has become a cauldron in which competing demands i.e. international tax coordination, national fiscal autonomy, and corporate ESG obligations are examined. The paper identifies key tensions (royalties versus covered taxes; double taxation risks; administrative capacity) and proposes policy responses. These measures aim to reconcile global tax fairness with the developmental needs of resource-rich states while embedding tax transparency within corporate governance frameworks.

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