Pre-Budget Briefing 2

Mining – June 2023

In brief
• 2022 highlights for the mining sector included
– USD2.8bn export earnings from gold
– In excess of USD 0.5bn in taxes, royalties and dividends to Government from the two largest gold mining groups (Barrick
(Twiga) and AngogoldAshanti (Geita))
– Growth in exports of coal and diamonds

• FYDP III targets for the mining sector by 2025/26 include:

– 10% share of GDP
– USD5.5bn foreign exchange earnings

• New investment:
– Recently signed framework agreements and issued special mining licences have set the platform for new mining projects
(gold, graphite, nickel, rare earths) to raise funding to move forward to development
– Potential investment in new mines exceeds USD3bn in the next two to three years

Fiscal matters: Resolution of various fiscal challenges facing the sector would help optimise its growth prospects. Highest
priority fiscal matters as regards prospective new investments include:
– Change in control provision (section 56 ITA 2004): exclude its application to mining companies that have not yet
commenced commercial production
– VAT refunds: automatic refund following receipt of the refund claim (supported by external auditor’s verification) with
the TRA audit to take place after the refund (rather than before).
– Royalty costs: clarificatory amendment to the legislation can be made to reconfirm / make absolutely clear that this is a
deductible cost for income tax purposes.

Background
Year ended 31 December 2022
In the year ended December 2022 gold continued to be the most significant contributor to exports, increasing by 3.4%
to USD 2,836.7m (2021: USD 2,743.1m; 2020: USD 2,957.5m), still ahead of tourism receipts in the period of USD 2,561m.
Total production of gold in 2022 was 1,359koz1 (2021 1,401koz).

FYDP III - 2025/26 targets

Tanzania’s third Five Year Development Plan (FYDP III of 2020/2021 to 2025/2026), issued in June 2021, sets out various targets
for the mining sector including an increase in share of GDP to 10% and annual foreign exchange earnings of USD5.5bn by
2025/26.

1 38,536 kg (2012: 39,725 kg) being cumulative total from BoT QEB

Tanzania Budget 2023/24

 Targets and Indicators for Mining Sector FYDP III Targets
2020/21 2025/26

Average growth rate (%) 6.9% 7.7%

Share to GDP (%) 5.6% 10.0%
Total foreign exchange earnings (USD million) USD 2,997m USD 5,505m
Raw exports v beneficiated (percentage) 15% v 85% 5% v 95%
Share of foreign exchange earnings 50.3% 50.5%

Page 2 | Tanzania Budget – Extractive 2023/24 PwC

Operating Mines – Gold - listed groups
The information set out below in respect of specific mines and mining groups is a summary of data taken from the
websites for Anglogold Ashanti (www.anglogoldashanti.com), Barrick Gold (www.barrick.com), Shanta Gold
(www.shantagold.com), and the Bank of Tanzania (www.bot.go.tz).

Production
In 2022 gold production from the international gold companies increased - in particular 521koz (2021: 486koz) from Anglogold
Ashanti group (Geita Gold mine) and 546koz (2021: 568koz from Barrick Gold / Twiga Minerals (North Mara and Bulyanhulu
mines as well as Buzwagi mine in 2021)).

Mineral resource
Year of All in
Total cash Mineral (measured,
Mine mine Production sustaining
costs reserve indicated and
opening costs
inferred)

2022 2021 2022 2021 2022 2021 2022 2021 2022 2021
‘000 ‘000 USD/ USD/ USD/ USD/ moz moz moz moz
oz oz oz oz oz oz
Geita2 2000 521 486 944 822 1,227 1,029 3.6 2.7 9.9 8.2
North Mara3 2002 313 309 741 777 1,028 1,001 3.6 3.3 6.6 5.7
Bulyanhulu4 2001 233 212 868 709 1,156 891 3.2 3.0 11.4 13.1
Buzwagi 5
2009 n/a 47 n/a 1,284 n/a 1,291
New Luika 6
2012 65 55 1,271 1,439 0.39 1.03
Singida7 2023 n/a n/a n/a n/a n/a n/a 0.23 0.89

There was no production from Buzwagi mine as mining operations ended in 2021.

In the 3 months to February 2023 Buckreef Gold had its first full quarter of gold production from its newly expanded processing
plant, following commercial production declaration in November 2022. Expected production for the 12 months to August 2023
is between 20koz to 25koz8.

Macroeconomic impact
In 2022 payments to Government continue to be significant, for example:

• Barrick9: USD295m tax contributions and royalties (2021: USD188m), and USD42m dividends to Government (2012: USD16m)
• Geita10: USD213m (2021: USD 242m; 2020: USD 326m).
Aside from the above, the sector continues to generate very significant wider multiplier effects - for example, the Barrick Tax
Contribution Report 2022 makes reference to USD882m economic contribution made in 2022 (2021: USD1.16bn),
and a separate report mentions payments to resident suppliers totalling USD 476m11.
2 Operational Profile 2022: Geita and Mineral Resource and Mineral Reserve Report 2022

3 Barrick - Q4 2022 Mine Statistics and Q4 2022 Results Presentation and Q4 2021 results presentation - the data shown above for mineral reserve and mineral resource is derived by applying 100/84 to the 84% effective ownership interest data reported in these documents.

4 Barrick - Q4 2022 Mine Statistics and Q4 2022 Results Presentation and Q4 2021 results presentation - the data shown above for mineral reserve and mineral resource is derived by applying 100/84 to the 84% effective ownership interest data reported in these documents.

5 Barrick - Q4 2021 Mine Statistics

6 Shanta Gold - 2022 Annual Report

7 Shanta Gold - 2022 Annual Report

8 TRX Gold - Q2 2023 results

9 Barrick Tax Contribution Report 2022 and Barrick Tax Contribution Report 2021

10 Operational Profile 2022: Geita

11 Barrick - Tanzania Q4 2022 Media Day

Page 3 | Tanzania Budget – Extractive 2023/24 PwC

Other highlights - Geita (Anglogold Ashanti (“AGA”))
In 2022 Geita’s gross revenues (USD920m) and gross profit (USD327m) represented 18.5% and 23.5% respectively of AGA
group revenues, and at the regional level Geita contributed 32% of production of AGA’s Africa region.

Looking forward the AGA Integrated Report 2022 highlights the following:

• Move to grid power (from diesel generation) by the end of 2023

• Mineral reserves have increased due to successes achieved by the exploration drilling programme at the mine.
Total additions over the past three years of 3.7Moz (including 1.5Moz in 2022) have added around seven years to
the life of mine.

Other highlights - Twiga (Barrick)

Highlights from the Barrick 2022 annual report include:

• In 2022 revenues from Tanzania (USD 1,033m) represented 9.4% of total group revenues
• New underground fleet at North Mara and Bulyanhulu continues to deliver on ramp-up plans
• Mining to start at the new Gena open pit in the first quarter of 2023
• Increased mineral reserves at Bulyanhulu and North Mara
• Presence in Tanzania was expanded through the acquisition of the Tembo licence, and plans to extend footprint further
through exploration licence consolidation.

Barrick’s Q4 2022 Mine Statistics report provides detailed analysis of mine statistics for each individual mine globally.
One statistic of interest, and indicative of Tanzania’s high royalty rate, is royalty as cost per ounce, which shows this cost in
2022 as significantly higher for Tanzania (North Mara USD127, Bulanhulu USD115) as compared to Barrick mines elsewhere in
Africa (Loulo-Gounkoto (Senegal) USD108, Kibali (DRC) USD85, Tongon (Mali) USD73) and Latin America (Veladero (Argentina)
USD74, Pueblo Viejo (Dominican Republic) USD58).

Operating Mines – Other

Coal
Coal exports for year ended December 2022 increased significantly to USD 160.4m (2021: USD13.2m) driven primarily
by increased demand for coal as an alternative source of energy to compensate for reduced supply of natural gas as a
consequence of the war in Ukraine. Destination countries included Poland, Hong Kong, India, Senegal as well as neighbouring
countries (Kenya, DRC, Rwanda, Uganda).

Diamonds
Diamond exports for year ended December 2022 increased significantly to USD 62.7m (2021: USD 8.5m) following the
resumption of production at Williamson Diamond Mine following a period of closure for maintenance.

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2

Page 5 | Tanzania Budget – Extractive 2023/24 PwC

Mines moving towards Development
Potential investment in excess of USD3bn
A number of new large scale mines are expected to be developed within the next two to three years, with anticipated investment
exceeding USD3bn. Most of these projects are in the process of raising funding for development. This follows the signature of
various framework agreements and / or issue of special mining licences including
the following:

• Nickel (Kabanga project) - USD1.3bn (per media reports)

• Gold (Nyanzaga project) - USD474m
• Rare Earths (Ngualla project) - USD321m
• Graphite - several projects - >USD1bn

Nickel - Kabanga project

Important developments in relation to Kabanga (described as “one of the world’s largest and highest quality nickel deposits”)
include the 13 December 2022 announcement12 of the planned listing of the New York Stock Exchange of Lifezone Metals
(“LZM”) (ultimate parent of Tembo Nickel). In addition on 9 December 2022 Tembo Nickel announced a further USD50m
investment commitment by BHP13 - so a total investment of USD100m including earlier USD50m investment. Investor
presentations14 15 indicate a final investment decision (“FID”) in late 2023 or early 2024, with targeted first ore in 2026.

Gold – Nyanzaga project

Recent investor updates16 17 mention that financing discussions are well advanced, and refer to a target for commencement of
production in the second half of 2025, with a projected production profile (average) of 242koz per annum over the first 10 years.
Nyanzaga will be the first large scale gold mine to open in Tanzania since Buzwagi
(which opened in 2009).

Rare Earths – Ngualla project

A March 2023 presentation18 describes this as “one of the largest and highest grade undeveloped rare earth deposits in the
world, with significant exploration and development upside”. In terms of indicative timelines, it refers to a target of July 2025 for
first concentrate assuming FID in July 2023 – but a more recent interview indicates an FID timeline of September 2023.

12 December 2022 announcement of planned listing

13 December 2022 announcement of additional BHP investment

14 LZM 17 April 2023 investor update

15 LZM 13 December 2022 investor update

16 Orecorp 7 March 2023 investor presentation

17 Orecorp - March 2023 quarterly activities report

18 Peak Rare Earths - March 2023 presentation - Ord Minnett East Coast Mining Conference

Page 6 | Tanzania Budget – Extractive 2023/24 PwC

Graphite projects – Bunyu, Chilalo, Epanko, Mahenge, Nachu, Lindi Jumbo
The interest in the graphite projects is driven by:

• Strong outlook for graphite demand given decarbonisation initiatives including the strong uptake of electric vehicles, and
• Quality of various graphite resources in Tanzania, allied to infrastructural and logistics advantages that ease access to such
resources

A number of recent presentations make reference to the quality of the resource, for example:

• Magnis describe the project as “one of the largest mineral resources of flake graphite in the world” and in regard to
the resource mention that the “very high purity is a key differentiator”19
• Blackrock state “Mahenge’s 213mt resource makes it the 4th largest graphite resource in the world”20

Many of these projects are looking to reach a final investment decision and financial close at some point in 2023.
On the basis that financial close is successfully reached, and with project construction periods of up to 20 months,
the expectation is for most of these projects to start production no later than 2025.

Mineral projects other than graphite

Overseas Listing Local entity Project name Framework SML grant Initial Initial
ultimate Agreement life of capital
holding mine expenditure
company (years)
Years USD’m
Nickel LifeZone Planned22 Tembo Nickel Kabanga 19 Jan 2021 27 Oct 2021 33 1,30021
(majority)
/ BHP
(minority)
Gold Orecorp22 ASX Sotta Mining Nyanzaga 13 Dec 2021 Dec 2021 10.7 474
Corporation
Ltd
Rare Peak ASX Ngualla Rare 17 April 25 April 24 32125
earths Resources Earth Project 202323 202324
Mineral Strandline26 27 ASX Nyati Mineral Fungoni project 13 Dec 2021 Fungoni - Fungoni Fungoni
sands Sands ML not SML 6.2 32.1m
Tajiri - SML Tajiri Tajiri 125m
Tajiri project pending 23.4

19 Nachu Graphite Project – BFS Update 2022 presentation

20 Black Rock Mining - March 2023 presentation - Paydirt Battery Materials Conference, Perth
21 Per Mining Journal article of 21 September 2021 shared on Tembo Nickel website
22 Orecorp 7 March 2023 investor presentation
23 Peak Rare Earths - ASX Announcement 18 April 2023
24 Peak Rare Earths - ASX Announcement 26 April 2023
25 Peak Rare Earths - March 2023 presentation - Ord Minnett East Coast Mining Conference
26 Strandline - March 2023 - Building a Significant Critical Minerals Business
27 Strandline - Quarterly Activities Report for December 2021

Page 7 | Tanzania Budget – Extractive 2023/24 PwC

 Graphite projects

Overseas ultimate Listing Local entity Project Framework SML grant Initial life Initial capital
holding company name Agreement of mine expenditure
(years)

Years USD’m
Blackrock Mining ASX Faru Mahenge 13 Dec 2021 7 Sep 202228 26 182m29
Limited Graphite
Project
EcoGraf ASX Duma Epanko 17 April Pending 18 134m
TanzGraphite Graphite 202330
Project
Evolution Energy ASX Kudu Chilalo 17 April Pending 17 120m
Minerals Graphite Graphite 202331
Project
Magnis Energy ASX Nachu 9 Sep 2015 15.5 364m
Technologies Graphite
Project
Volt Resources ASX Bunyu Pending 22 31.6m (stage 1)
Graphite
173m (stage 2)
Walkabout ASX Lindi Pending 32
24 33m
Resources Jumbo
Graphite
Mine

28 Black Rock - 7 September 2022 announcement

29 Black Rock Mining - March 2023 presentation - Paydirt Battery Materials Conference, Perth
30 EcoGraf - 18 April 2023 announcement
31 Evolution Energy Minerals - 18 April 2023 announcement
32Walkabout Resources - Quarterly Report to December 2022

Page 8 | Tanzania Budget – Extractive 2023/24 PwC

2023/24 Budget - Tax matters to consider for Mining Sector
The mining sector is a complex one - and one of the complexities relates to taxation. With the 2023/24 Budget to be read this
month, we summarise some of the tax concerns for the mining sector and potential solutions. We have categorised the issues
under three broad banners related to mining operation maturity as follows: (i) Fundraising (ii) Development (iii) Operational.

Fundraising
For a more detailed analysis of the issues refer to our May 2021 briefings as follows:

• Pre-Budget Tax Briefing 5: Change in Control33

• Pre-Budget Tax Briefing 6 - Extractive Sector Transactions 34
Set out below is a summary of the issues related to fundraising transactions.

Issue Proposed Solution

Change in Control - Section 56 ITA 2004

In 2012 an amendment was made to s56 to enable taxation of indirect disposals (where To exclude from the scope of
the underlying ownership change was overseas). Although the amendment was well section 56 any entity engaged in
intentioned - namely to counter tax avoidance - its effect is much wider than originally mining operations (or petroleum
intended; in particular, as currently drafted, it could apply to project funding raised operations), and that has not yet
through the issuance of shares (if the consequence is a change of underlying ownership started commercial production of
(i.e. ultimate shareholders) of more than 50%). Left unchanged it will make it more minerals (or petroleum).
difficult to raise funding for mining projects.
The overall aim here would be to
exclude extractive sector assets
not yet at production stage from
the application of section 56,
Farm In Transactions

Changes made in 2016 treat a “commitment to spend” by a “farmee” as income derived Amounts brought into tax as
by the “farmor” for disposal of an interest in the mineral (or petroleum) right with income on a farm in transaction
such income valued at the present value of future expenditure commitments, act as a should be limited to cash receipts
disincentive to investment in exploration . (if any) paid to the farmer and
exclude any value for future
(By way of background transactions that take place at the exploration stage sometimes expenditure commitments of
involve a “farm in” / “farm out”, whereby a “farmee” (future transferee who “farms in”) the farmee.
has a right to earn an interest in an asset held by the farmor (future transferor who “farms
out”) if certain project expenditure commitments are met by the farmee. The essence of
the transaction is that new capital is introduced to fund project expenditure in exchange
for which an interest in the asset is earned.)

33 https://www.pwc.co.tz/assets/pdf/tax-alert-pre-budget-tax-briefing-5-change-in-control.pdf
34 https://www.pwc.co.tz/assets/pdf/tax-alert-pre-budget-tax-briefing-6-extractive-sector-transactions.pdf

Page 9 | Tanzania Budget – Extractive 2023/24 PwC

 Issue Proposed Solution
Realisation of an interest in a mineral right

Since July 2016 the realisation of an interest in a mineral right (and in a petroleum right) Reverse the 2020 amendment by
is subject to a similar upfront clearance and tax payment process at the time of the removal of subsection
transaction (by reference to the single instalment tax provision - Section 90 ITA 2004). In (9) of Section 90.
2020 a separate definition of “realisation” was introduced for the purposes of section 90,
by way of a new sub-section (9), which states that “for purposes of this section, ‘date of
realisation of an interest’ means-

(a) the date of execution of contract for sale;

(b) the date of parting with possession, use or control of a realised asset; or

(c) the date of payment of part or whole of the consideration for the realised asset,
whichever comes earlier.”

This creates a practical challenge as:

• The reality is that many contracts are conditional, and may not proceed to conclusion
if the specified conditions are not satisfied.
• It contradicts the income recognition rules as set out elsewhere in ITA 2004 (in
particular, sections 23 and 39).
Ring fencing – exploration stage

The effect of current ring fencing rules (with a ring fence by licence area) is that Exclude the application of a ring
exploration costs on unsuccessful prospecting licences in effect become stranded and fence to exploration costs.
therefore receive no tax relief, and as such act as a disincentive to exploration.

Page 10 | Tanzania Budget – Extractive 2023/24 PwC

 Issue
Economics

Payments to the Government calculated by reference to profit (namely, 30% corporate tax, a minimum 16% Government free
carry interest (“FCI”), and 10% dividend withholding tax) on their own (without considering turnover based payments, such as
royalty) automatically represent 47% of profit before tax.

Payments to Government excluding royalty and other turnover based levies

Rate USD
Profit before tax 100
Income Tax 30% -30
Profit after tax 70
Free Carry Interest 16% -11
Profit after FCI 59
Withholding Tax on Dividends 10% -6
Net dividend 53

Payments to Government including royalty and other turnover based levies

Once the turnover based taxes are taken into account - in the case of gold 7.3% (namely royalty 6% (being the “metallic
minerals” rate), inspection fee 1%, and service levy 0.3%), the resulting overall effective tax rate / Government take can easily
increase to in excess of 70% - for example, in the case of gold, a study in January 2019 by the Natural Resource Governance
Institute modelled a Government take of 74%35. The actual total effective tax rate depends on project profitability, with an
inverse relationship between the two (as a consequence of turnover taxes).

So as to maximise investment in the sector, there is a need to ensure that the country’s fiscal aspirations do not conflict
with the realities of project economics and the need for an appropriate investor return. Otherwise, the risk is that only
exceptionally high margin projects can move to development.

Proposed Solution
Downward adjustment to royalty rate for metallic minerals gold (currently 6%).

Removal of inspection fee (1%).

Credit for withholding tax on dividends against liability in respect of payments due to the Government under Free Carry
Interest, such that FCI payment is reduced to the extent of any withholding tax on dividends paid or to be paid in respect of
dividends already declared or paid.

35 https://resourcegovernance.org/blog/magufuli-seeks-right-balance-tanzania-mining-fiscal

Page 11 | Tanzania Budget – Extractive 2023/24 PwC

Development
Set out below is a summary of the issues related to the development

Issue Proposed Solution

VAT refunds

As noted above, in excess of USD3bn will be potentially For large projects (with capital expenditure of say USD 100m
invested by the sector. VAT will apply to all supplies of goods or more) provide for an automatic refund following receipt of
and services to the mining entities other than imports by the refund claim (supported by external auditor’s verification)
them (which will normally be exempt). If we assume that say with the TRA audit to take place after the refund (rather than
two thirds of the spend is VATable, this would imply VAT of before).
USD360m (18% x USD2bn) to be refunded over the course
of the next two to three years while the mines are being
constructed.

Much as there is acknowledgment of the significant

improvement in the VAT refund process, given the magnitude
of the sums involved the concern is as to financing costs that
mining entities would incur in relation to any delay in refunds.
Taxes on imports by subcontractors

Exemptions from taxes on import (including customs duty) Extend exemption to subcontractors for imports exclusively
apply to the mining company but not their subcontractors. required for the relevant mining project.

Page 12 | Tanzania Budget – Extractive 2023/24 PwC

Operational
Set out below is a summary of the issues related to once a mine is in production..

Issue Proposed Solution

USD accounting Technical: An amendment to make such an election a right
for extractive sector companies (bearing in mind that USD is
Technical: The ITA 2004 provides (in Section 28(4)) for the the normal functional currency for such entities).
possibility of making an election for foreign currency tax
accounting, such grant and its period of application is at Procedural: For so long as systems do not accommodate
the discretion of the TRA. By contrast the predecessor filing other than in TZS, then identify a practical mechanism
legislation (ITA 1973 section 61(4)) provided a right to mining to arrive at the same economic result notwithstanding TZS
companies to elect to file tax returns in USD (the normal filing - for example, an annual rebasing of brought forward
functional currency for mining entities) and such election once unrelieved expenditure (tax losses and tax written down
made was irrevocable; it also was quite prescriptive as to the values) by reference to the exchange rate movement - so
consequences of the election. that as to align the TZS value of taxable profit with the USD
value of taxable profit based on the exchange rate applicable
Procedural: A further challenge is procedural as TRA for the period for which the taxable profit is assessed.
electronic systems are configured to only accept TZS
numbers.
Deduction - royalty costs

There is a technical dispute in relation to deduction of royalty Ideally, the TRA would revisit the technical interpretation in
costs. The TRA position is that it is no longer deductible this regard.
following a 2017 amendment to the section dealing with
deduction of expenses to expressly remove a reference to Alternatively, so as to avoid ongoing disputes on
royalty (which was first introduced in 2016). Our view is that interpretation, then a clarificatory amendment to the
royalty is deductible for the following reasons: legislation can be made to make absolutely clear that this
is a deductible cost (in line with industry interpretation and
• It does not require a specific mention in the deduction consistent with normal global practice).
provision as it is deductible on general principle (as a cost of
the business) - an interpretation not disputed by TRA prior
to 2016, and an interpretation consistent with interpretation
in other mining jurisdictions (as to royalty being a cost
“incurred in the production of income”).
• For royalty to not be deductible it would need to be
expressly stated as non-deductible in the section dealing
with disallowable expenditure.
• This interpretation is inconsistent with the tax treatment
of other turnover based levies (service levy paid to local
authorities; various regulatory levies paid to industry
regulatory bodies).
• The add back of such a significant cost would in effect
apply a profit based tax to a sum much higher than the
economic profit
• The practical impact of such an adjustment would be to
de facto increase royalty rates by 30% - if this had been
the intention, then the royalty rate itself would have been
amended.

Page 13 | Tanzania Budget – Extractive 2023/24 PwC

 Issue Proposed Solution
Deduction - CSR costs

Mining companies view corporate social responsibility (CSR) An amendment to include an express deduction for
costs as part of their “licence to operate”, and so a business CSR costs to the extent incurred due to an obligation
cost. Historically, TRA have viewed CSR costs not as business imposed by law.
costs but more in the nature of donations and therefore subject
to the deduction restrictions applicable to donations (cap of
2% of taxable income). However, amendments made in 2017
to the Mining Act 2010 in effect make the incurring of CSR
costs a legal requirement, and as such this is a mandatory
cost incurred in the production of income. Nevertheless, TRA
continues to treat such costs as more in the nature of voluntary
contributions.
Ring fencing – contiguous operations

Ring fencing is by licence area irrespective of if two licences Exclude the application of the ring fence to licences
are contiguous and / or effectively part of the same economic that are contiguous and / or effectively part of the same
project. economic project

Page 14 | Tanzania Budget – Extractive 2023/24 PwC

Our Mining Sector Contacts
David Tarimo Joseph Lyimo Redempta Maira
Partner/ Director – Tax Services Partner/ Director – Indirect Tax Senior Manager – T​ ax Services
T: +255 22 219 2600 T:+255 22 219 2613 T: +255 27 254 2816
M: +255 754 784 844 M:+255 767 992 506 M: +255 754 301 007
david.tarimo@pwc.com joseph.lyimo@pwc.com willie.w.kimaro@pwc.com

Patrick Kiambi Sarah Bisanda Chacha Winani

Partner/ Director – A
​ ssurance Leader Associate Director – A
​ ssurance S
​ ervices Associate Director – Advisory Services
T: +255 22 219 2000 T: +255 22 219 2000 T: +255 22 219 2000
M: ​+255 767 500 742 M: ​​+255 746 294 861 M: +255 756 223 377
kiambi.patrick@pwc.com sarah.bisanda@pwc.com chacha.winani@pwc.com

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