Exxaro Resources Limited
Tax report for the year ended 31 December 2022

Country-by-country information

Exxaro Resources, as the ultimate parent of a Multinational Enterprise and reporting entity, is responsible for the preparation and submission of the country-by-country report for the Exxaro group in South Africa. The master file has been prepared in accordance with commentary in chapter V of the 2017 Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations issued by the Organisation for Economic Co-operation and Development, and in line with the requirements of the public notice published by SARS for the submission of the country-by-country report, master file and local file by persons specified therein.

Exxaro is a diversified resources group with business interests in South Africa, Switzerland, China, Australia and Israel. Refer to about Exxaro for a description of Exxaro's key business areas locally.

Refer to the annual financial statements for a full list of Exxaro's entities per jurisdiction.

Offshore business areas


Coal extracted from the South African mines is sold into the overseas markets through the Swiss marketing company, EITAG, which is Exxaro's central offshore sales company. EITAG buys coal from Exxaro Coal and Exxaro Coal Mpumalanga and on-sells the coal products to the ultimate customer. The goods are delivered to Richards Bay Coal Terminal Proprietary Limited (RBCT) and other ports and, from there, directly to the foreign customer. EITAG is responsible for the coal blending process as well as the RBCT port cost.

EITAG attracts new customers and develops new markets for Exxaro coal products. Based on the contract concluded with customers, EITAG manages the scheduling of coal volumes, quality types and shipping dates.

EITAG's business strategy is to use the following regional advantages:

  • Proximity of clients
  • Intelligence gathering
  • Product and market knowledge
  • Access to ports to facilitate efficient logistics
  • Cultural fit with customers

Having a central offshore sales company ensures the application of consistent policies and the growth of the Exxaro brand and offshore customer base. EITAG has five employees (one expat employee, one local employee and three contractors).


Exxaro Australia Holdings Proprietary Limited (EAH) is the holding company of the Australian group of companies (the EAH Australian tax group) and does not have any employees. Exxaro Australia Proprietary Limited, a subsidiary of EAH, holds a 50% interest in a joint venture with Anglo Coal (Grosvenor) Proprietary Limited (Anglo Coal) in the Moranbah project, which is currently an undeveloped coal resource in exploration stage. Anglo Coal manages the project.

The Moranbah project is located in the Queensland district of Australia.


Exxaro holds a minority investment in the Chifeng Hongye Zinc Smelting Co Limited smelting operations, incorporated in China.

United Kingdom (UK)

Exxaro owns a 25.85% interest in Insect Technology Group Holdings UK Limited, which is currently in the process of deregistration.


Exxaro owns a 28.01% interest in LightApp Technologies Limited.

Significant intercompany transactions

Important service arrangements within the Exxaro group are shown in the table below. During 2022, there were no loans between Exxaro and any of its foreign group companies outside South Africa. Exxaro does not maintain unilateral advance pricing agreements in support of its intercompany transactions, or tax rulings relating to the allocation of income across countries.

Service Supply entity Supply country Receiving
Sale of coal Exxaro Coal and Exxaro Coal Mpumalanga South Africa EITAG Switzerland Yes
Provision of warehousing, logistics and blending support Exxaro Coal South Africa EITAG Switzerland Yes
Provision of various business and management support services, including but not limited to:
  • Financial and accounting services
  • Human resources
  • Legal and insurance services
  • IT, purchasing, business developments, operations and quality assurance
  • Communication and regional management services
Exxaro Resources South Africa Various South Africa Not applicable

Country-by-country reporting for the year ended 31 December 2022

Revenue from 
Revenue from  
transactions with  
before tax2
tax paid/ 
in cash 
tax expense 
South Africa 
Coal  23 581  20 524  14 273  1 892  3 802  3 456 
Ferrous  224  19 
Base metals  578  578 
Iron ore  4 077  4 077 
Renewable energy  1 159  263  10  10 
Other  15  22 216  272  244 
Intercompany sales  (20 524)
Elimination  (19 528)
Total  24 979  –  21 898  6 547  4 086  3 710 
Switzerland (coal)
Coal – EITAG  21 390  453  24  54 
Australia (coal) (77)
Israel (energy) 18  (70)
Grand total  46 369  –  22 292  6 477  4 110  3 764 
tax accrued5
tax paid 
Statutory tax 
Effective tax 
number of  
South Africa 
Coal  28%  6 148  31 531 
Ferrous  28%  78  32 
Base metals 
Iron ore  28% 
Renewable energy  28%  24  5 348 
Other  493  412 
Intercompany sales 
Elimination  28% 
Total  28%  19.23%  6 743  37 323 
Switzerland (coal)
Coal – EITAG  10  10  12%  12%  – 
Australia (coal) 123 
Israel (energy)
Grand total  11  11  19.23%  6 745  37 446 
1 Excludes fees received for administration services delivered by the Exxaro Coal head office.
2 Equity-accounted investment income is included in net profit/(loss) before tax
3 Equity-accounted investment income is reflected in the country of incorporation. Income is after-tax income.
4 The number of employees consists of permanent employees. It does not include full-time equivalents and contractors.
5 Deferred tax has been excluded from the total corporate tax expense therefore normal corporate tax expenses accrued represents only current tax expenses accrued.


Opinions expressed herein are, by nature, subjective to known and unknown risks and uncertainties. Changing information or circumstances may cause the actual results, plans and objectives of Exxaro Resources Limited (the company) to differ materially from those expressed or implied in the forward-looking statements. Financial forecasts and data given herein are estimates based on the reports prepared by experts who, in turn, relied on management estimates. Undue reliance should not be placed on such opinions, forecasts or data. No representation is made as to the completeness or correctness of the opinions, forecasts or data contained herein. Neither the company, nor any of its affiliates, advisers or representatives accepts any responsibility for any loss arising from the use of any opinion expressed or forecast or data herein. Forward-looking statements apply only as of the date on which they are made, and the company does not undertake any obligation to publicly update or revise any of its opinions or forward-looking statements, whether to reflect new data or future events or circumstances. Any forward-looking information has not been audited, reviewed or otherwise reported on by the external auditors.

Report SelectorReport Index

Generate your own report

You can create your own custom PDF version of the report.

Select your areas of interest from the list below and submit your selection to create a PDF ready for you to download.

Exxaro Resources Limited Tax report
Add section
About Exxaro
Statement from the finance director
Our tax contribution at a glance
Tax approach
Tax governance
Tax risk management
Tax performance
Country-by-country information