Sustainable Landscape Finance Coalition Innovation Hub Finance Solution Incubator: BMA Tax Incentive Investigation| Report

The Sustainable Landscape Finance Coalition's BMA Tax Incentive Incubator investigated the legal and practical requirements to implement a long-unused tax incentive under the Income Tax Act and NEMBA. The investigation concluded that all necessary 'building blocks' are present, leading to a pilot project (July 2021 – June 2022) focusing on rhino and lion conservation. The project aims to test the incentive with voluntary landowners to offset conservation management costs, with estimated economic benefits growing from R1.4 million per annum in 2022 to R3.7 million by 2040.

• The section 37C(1) tax incentive within the Income Tax Act No. 58 of 1962, designed for Biodiversity Management Agreements (BMAs) under section 44 of the National Environmental Management: Biodiversity Act No. 10 of 2004 (NEMBA), has remained unused since 2009 because no BMAs had been created in South Africa.
• Legal analysis determined that BMAs do not strictly require publication in the Government Gazette under NEMBA, though the Minister has discretion to do so under the Interpretation Act 1957. However, if an agreement constitutes 'administrative action' that adversely affects public rights, publication and consultation are required under the Promotion of Administrative Justice Act 2000 (PAJA) and NEMBA sections 99 and 100.
• The BMA Tax Incentive Pilot Project, running from 1 July 2021 to 30 June 2022, targets the rhino and lion communities of practice. It aims to test the tax incentive in at least one tax return of a qualifying taxpayer, engaging a minimum of three voluntary landowners for each species to offset management costs.
• The BMA tax incentive is identified as a 'Candidate Other Effective Area-Based Conservation Measure (OECM)', meaning its implementation could contribute to South Africa's area-based conservation targets.
• Economic projections suggest the BMA Tax Incentive will generate increasing annual benefits, starting at approximately R1.4 million in 2022, rising to R2.7 million by 2030, and reaching R3.7 million by 2040.

APA

WWF South Africa (n.d.). Sustainable Landscape Finance Coalition Innovation Hub Finance Solution Incubator: BMA Tax Incentive Investigation| Report. https://wwfafrica.awsassets.panda.org/downloads/incubator_bma_tax_incentive_investigation_report_final.pdf

Chicago

WWF South Africa. Sustainable Landscape Finance Coalition Innovation Hub Finance Solution Incubator: BMA Tax Incentive Investigation| Report. n.d. https://wwfafrica.awsassets.panda.org/downloads/incubator_bma_tax_incentive_investigation_report_final.pdf.

Wikipedia

{{cite report |author=WWF South Africa |title=Sustainable Landscape Finance Coalition Innovation Hub Finance Solution Incubator: BMA Tax Incentive Investigation| Report |url=https://wwfafrica.awsassets.panda.org/downloads/incubator_bma_tax_incentive_investigation_report_final.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{wwfsouthafricandsustainable, author = {{WWF South Africa}}, title = {{Sustainable Landscape Finance Coalition Innovation Hub Finance Solution Incubator: BMA Tax Incentive Investigation| Report}}, institution = {WWF South Africa}, url = {https://wwfafrica.awsassets.panda.org/downloads/incubator_bma_tax_incentive_investigation_report_final.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }