Mining taxation is a very topical issue in mineral resource rich countries in Africa. This discussion has caught the imagination of citizens of many countries that question the fairness of the sharing of revenue between the investors and the state representing the citizenry. Often the debate is not well served by discussions that do not fully capture all the elements of the mining business, such as the long gestation period as well as the high capital input required. It is considered that a review of the fiscal regime of Zambia, and neighbouring mineral rich countries, would help inform the debate on the sharing of revenue from mineral resources. Further, such an analysis could present an opportunity for proposing what an “ideal” tax regime could be, and the critical elements of such a tax structure, and how it could be implemented.