The new Mining Tax Law further establishes that mining rights are considered immovable property and that all capital gains, arising from the direct or indirect transfer of mining rights, by nonresident entities with or without permanent establishment in Mozambique, will be taxable at a fixed rate of 32%. This capital gains tax shall become due and payable by the seller or transferor but the purchaser and the Mozambique entity holding the mining rights has several and joint liability for the payment of the tax. In case of doubt on the price of the transaction, the tax authorities may refer to best international practices to determine the price