Not to hard for a tax planner to beat the super profits tax. Depends on the strength, if any of the DRCs tax transfer pricing rules and CFC (profit attribution) rules. For example, do as some of the big Australian miners do and set up a marketing hub in Singapore. Pay a marketing fee to the Singapore entity. Good for 3% of retail price. Chip away with other costs, fees and charges to strip profits out of the DRC operating entity.
Accounting tricks such as faster amortisation and depreciation of assets can smooth out profits. Tricks such as not capitalising labor might help.
All depends on how they are measuring super profits.
ATO didn't collect much mining tax because it was easy to manipulate.
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