7th September 2026
For many years, the large historic balances sitting in Aminex’s accounts have attracted relatively little attention from investors. With Ntorya approaching production, that could be about to change. Expenditure accumulated during the long journey from exploration towards development may have created tax losses capable of reducing future Tanzanian corporation tax, while substantial intercompany funding provides a potential route for post-tax cash generated by Ndovu Resources to return to its parent company.
Neither mechanism creates additional gas or increases the price Aminex receives for it. What they could do is influence how much of the cash generated from Aminex’s 25% interest in Ruvuma ultimately remains within the Group during the early years of production.
The numbers involved are sufficiently large to make that worth examining.
Aminex’s 2025 Annual Report records total Group tax losses of approximately $122.4 million. These comprise $16.8 million in Ireland, $26.4 million in the UK and $79.2 million classified as Rest of World.
Those numbers cannot simply be added together and deducted from future Ntorya profits. Tax losses are subject to the rules of the jurisdiction in which they arose, and Tanzania applies an additional restriction to petroleum operations. Losses associated with one petroleum licence area cannot simply be transferred to another petroleum licence area.
For Aminex investors, the important figure is therefore not the entire $122.4 million, nor necessarily the entire $79.2 million Rest of World balance. It is the proportion of those losses that relates specifically to the Ruvuma petroleum operations and remains available for use against future taxable Ruvuma profits.
Aminex does not provide that licence-by-licence breakdown in its published accounts, so the precise Ruvuma figure cannot currently be established from the Annual Report. Nevertheless, given the Group’s long history of expenditure on Ruvuma, the existence of a potentially material qualifying loss pool deserves attention as production approaches.
Tanzania allows qualifying carried-forward losses to reduce future taxable profits, but current rules limit the amount that can be used in any one year. For petroleum operations, brought-forward losses can offset up to 60% of taxable profit, leaving at least 40% exposed to corporation tax.
With Tanzania’s normal corporation tax rate at 30%, the arithmetic produces an interesting result. While sufficient qualifying Ruvuma losses remain available, the cash corporation tax payable could effectively equate to approximately 12% of taxable profit before utilisation of those losses.
Consider a deliberately simple example. If Ndovu generated $10 million of taxable Ruvuma profit before brought-forward losses, it could potentially use $6 million of qualifying losses. That would leave $4 million subject to 30% corporation tax, producing a tax charge of $1.2 million.
The remaining unused losses would continue to be available for future periods, subject to the applicable rules.
This does not change Tanzania’s corporation tax rate from 30% to 12%. Rather, it illustrates the effective cash tax outcome that could arise while sufficient qualifying historic Ruvuma losses remain available.
This is where modelling can help, provided the assumptions are kept clearly separate from established facts.
We know from Aminex's accounts that the Rest of World tax-loss balance is approximately $79.2 million. What we do not know from the published breakdown is how much of that relates specifically to Ruvuma.
For illustration, suppose the qualifying Ruvuma loss balance were $60 million. That is not a figure Aminex has published and should not be treated as an estimate of the actual balance. It is simply a modelling assumption that allows us to show how the mechanism could work over time.
The important point is that Tanzania's 60% utilisation limit applies to each year's taxable profit, not to the remaining balance of historic losses.
If Ndovu generated $10 million of taxable Ruvuma profit before brought-forward losses, it could potentially use up to 60% of that year's profit, or $6 million, from the historic loss pool. That would leave $4 million subject to corporation tax.
At Tanzania's 30% corporation tax rate, tax for that year would therefore be:
$10m profit
less $6m historic losses used
= $4m taxable
30% tax on $4m = $1.2m
The historic loss pool would then fall from $60 million to $54 million.
If taxable profit were again $10 million the following year, another $6 million of losses could be used. The remaining loss pool would fall to $48 million, and so on.
The relationship is simple:
60% of each year's taxable profit can be offset against the qualifying historic loss pool, until that pool is exhausted.
The 60% is therefore recalculated each year according to the profit generated in that year. It is not calculated as 60% of the remaining loss balance.
If annual taxable profit were higher, the losses would be used more quickly. For example, with $70 million of taxable profit and $60 million of losses available, the maximum deduction would be 60% of $70 million, or $42 million. That would leave $28 million subject to corporation tax and reduce the remaining loss pool to $18 million.
Across the ten-year example above, Ndovu would have generated $100 million of cumulative taxable profit before brought-forward losses and used the entire illustrative $60 million historic loss pool.
The result would be:
$100m cumulative profit before losses
$60m historic losses utilised
$40m subjected to corporation tax
$12m corporation tax paid
Without the historic losses, 30% tax on the same $100 million would have amounted to $30 million.
In this simplified model, the qualifying historic losses therefore produce an $18 million corporation-tax saving during the period in which they are being utilised, leaving more cash within the business during the early profitable years.
The actual outcome will depend on the size of the qualifying Ruvuma loss pool, production volumes, revenues, operating costs and resulting taxable profits. The value of the model is that it shows how a historic loss balance can continue reducing the cash tax burden year after year until it has been fully used.
Aminex also has approximately $16.8 million of Irish tax losses. These belong within the Irish tax jurisdiction and cannot be used to reduce the Tanzanian taxable profits generated by Ndovu.
They may nevertheless have value at Aminex plc level if the company generates suitable taxable Irish profits against which those losses can legitimately be utilised. Their eventual usefulness will depend upon the nature and location of future Group income.
They should therefore be regarded as a separate potential Group tax asset rather than part of the Ntorya corporation-tax calculation.
The second part of the story concerns the way Aminex has historically financed its subsidiaries.
At the end of 2025, Aminex plc reported approximately $146.6 million of gross amounts due from subsidiary undertakings. Following an impairment provision of approximately $41.7 million, the balance carried in the parent-company accounts was approximately $104.9 million.
The accounts describe these intra-group loans as interest-free and repayable on demand, while the recoverability assessment is closely linked to future revenues expected from the Group’s Tanzanian assets. The Audit Committee also specifically discusses the intercompany loan due from Ndovu Resources.
This creates an interesting potential route for future cash generated at Ntorya.
Aminex has spent many years funding its Tanzanian activities through its subsidiary structure. As Ndovu begins generating sufficient post-tax cash from production, repayment of legitimate outstanding intercompany loan principal could reverse some of that historic flow, returning capital to Aminex plc.
Normally, when a profitable subsidiary distributes earnings to its overseas parent through a dividend, withholding tax may be deducted before the cash leaves the country. Tanzania generally applies a 10% withholding tax to dividends paid to non-residents.
Repayment of genuine loan principal is different. It represents repayment of money previously advanced rather than a distribution of profit as a dividend. Aminex’s intra-group loans are also stated to be interest-free, avoiding the need to mix principal repayment with an interest stream when considering the existing balances.
A simplified illustration shows why this could become important. If $100 of post-tax cash were distributed as a dividend subject to 10% withholding tax, approximately $90 would reach the parent company. If the same $100 could legitimately be applied to repayment of outstanding intercompany loan principal, approximately $100 could instead return as repayment of capital.
That does not mean every dollar of future Ndovu cash will necessarily be remitted this way. The subsidiary will require cash for its own operations, obligations and continuing investment, while any repayment must comply with the applicable Tanzanian corporate, tax, banking and regulatory requirements.
Nevertheless, with a gross parent-company intercompany receivable of $146.6 million and a net carrying value of $104.9 million, the potential capacity is substantial.
The particularly interesting point for Aminex shareholders appears when the tax-loss position and intercompany funding are considered together.
During the early profitable years of Ntorya, qualifying historic Ruvuma losses could potentially reduce the immediate corporation tax burden. After tax and the other requirements of the business have been met, some available cash could then potentially be used to repay historic intercompany funding to Aminex plc rather than relying entirely upon dividend distributions.
The journey of a portion of future Ntorya cash could therefore look broadly like this:
Ntorya revenue → taxable Ruvuma profit → qualifying historic losses utilised → reduced early cash corporation tax → post-tax cash generated by Ndovu → repayment of intercompany loan principal → cash returned to Aminex plc.
This is not financial engineering created for the arrival of Ntorya production. It is largely the consequence of Aminex’s history. The Group has accumulated expenditure and losses while developing its Tanzanian interests, and Aminex plc has provided substantial funding to its subsidiaries over that same period.
Production potentially turns those historic balances from accounting footnotes into economically relevant assets.
There is another reason the intercompany balance deserves attention. Aminex’s directors have retained a net carrying value of approximately $104.9 million for amounts due from subsidiaries after impairment, and their assessment of recoverability is principally dependent upon the future development and cash generation of Ntorya.
In other words, the relationship between Ntorya and the intercompany balance is not merely an interpretation being placed on the accounts by investors. Future Tanzanian revenues already form an important part of the accounting assessment supporting the recoverability of those balances.
As Ntorya moves from development towards production, investors should consequently be able to watch that relationship evolve from an accounting valuation based upon future cash-flow expectations towards actual cash generation.
Aminex shareholders naturally concentrate on the most visible drivers of future value: gas volumes, production rates, the gas sales price, drilling results and the speed with which Ntorya can be expanded. Those remain fundamental, but they do not by themselves determine how much cash ultimately becomes available to Aminex plc.
The Group’s historic financial position could provide an additional advantage during the early production years. Qualifying Ruvuma tax losses have the potential to reduce the immediate Tanzanian corporation-tax burden, while substantial historic intercompany funding may provide an efficient mechanism through which available post-tax cash can return to the parent company.
The precise value cannot yet be calculated because Aminex does not disclose how much of the $79.2 million Rest of World tax-loss balance relates specifically to Ruvuma, and future taxable profits themselves remain unknown. That uncertainty does not diminish the underlying mechanism; it simply means any attempt to quantify it today must remain a model rather than a forecast.
After years in which historic expenditure represented the cost of reaching this point, Ntorya production could begin to reveal another side to that legacy. Some of the financial history accumulated while developing the field may now help Aminex retain and recover more of the cash that the field generates.
Contributing Author: Andrew Eldridge and Ufufuo