transfer pricing in the mining sector

Assessing Transfer Pricing Risk in the Mining Industry

Assessing Transfer Pricing Risk in the Mining Industry

Assessing Transfer Pricing Risk in the Mining Industry How BEPS Is Changing the Landscape. Mining companies have global operations and face unique tax challenges from a transfer pricing perspective. With the introduction of the OECD/G20s Base Erosion and Profit Shifting (BEPS) Project in 2013, these challenges are likely to intensify. The training program on Transfer Pricing in the mining sector included a virtual component, which proposed an introduction to the subject of transfer pricing determination methods, compatibility and administrative control aspects concerning transfer pricing. In addition, the whole issue of the value chain in the mining industry was treated.

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Transfer Pricing In The Mining Sector

Transfer Pricing In The Mining Sector

Part A (The mining industry and transfer pricing) identifies what are the most common transfer pricing issues in mining in general and where they are likely to occur along the mining value chain. Part B (The mining industry in Africa and transfer pricing) considers the same issues specifically in the context of the main commodities currently ... transfer pricing compliance in the mining sector. For guidance on how to adjust foreign comparable data for country and taxpayer conditions and risks, tax authorities should refer to a toolkit for Addressing Difficulties in Accessing Comparables Data for Transfer Pricing Analyses published by the Platform for Tax Collaboration in June 2017. 3

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Transfer Pricing in Mining with a Focus on Africa A

Transfer Pricing in Mining with a Focus on Africa A

Dec 27, 2017 In Tanzania, for example, the Acasia Mining Plc. was recently issued a USD 190 billion tax bill. The assessment demonstrates a strong political will in Africa to address transfer pricing non-compliance. A paper commissioned by the World Bank highlights transfer pricing issues within the African Mining industry. The transfer pricing manipulation problem is characterised by Multinational Enterprises (MNEs) who are centred to operate as strategic business entities. This problem has become even more serious as many companies have subsidiaries extended all over

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Toolkit for Transfer Pricing Risk Assessment in the

Toolkit for Transfer Pricing Risk Assessment in the

loss in the mining sector. The programme will cover the following issues 1. Excessive Interest Deductions 2. Abusive Transfer Pricing 3. Undervaluation of Mineral Exports 4. Tax Incentives 5. Tax Stabilisation 6. International Tax Treaties 7. Offshore Indirect Transfers of Mining Assets 8. Metals Streaming 9. Abusive Hedging Arrangements 10 ... Transfer Pricing Challenges mining companies face. The mining industry poses some very specific challenges from a transfer pricing point of view. South African mining groups are often involved at more than one level in the supply chain. For example, the group may both mine and beneficiate the

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Africa Mining and Transfer Pricing

Africa Mining and Transfer Pricing

Mar 08, 2017 Transfer pricing has emerged as a key area of capacity building for African governments. Responding to this and within the context of the African Mining Vision and the Report of the High Level Panel on Illicit Financial Flows from Africa (the Mbeki Report), the Africa Minerals Development Centre (AMDC) in partnership with the World Bank has commissioned the Mineral and Accessing Comparables Data for Transfer Pricing Analyses Including a supplementary report on Addressing the Information Gaps on Prices of Minerals Sold in an Intermediate Form International Monetary Fund (IMF) ... BUILDING AN UNDERSTANDING OF THE MINING SECTOR ...

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The Causes and Effects of Transfer Mispricing in Mining

The Causes and Effects of Transfer Mispricing in Mining

Sep 28, 2017 Authorities can identify and assess transfer pricing risks in the mining sector, select the most high-risk cases for audit, and protect the mining tax base against profit shifting. Mar 18, 2021 As a result of the mining tax audit capacity building initiatives, the Mongolian Tax Administration issued its first transfer pricing tax assessment in late 2020 for approximately USD 228 million and a denial of USD 1.5 billion in carried forward losses.

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Tax Incentives in Mining Minimising Risks to Revenue

Tax Incentives in Mining Minimising Risks to Revenue

Transfer Pricing in the Mining Sector Preventing Loss of Income Tax Revenue into two categories (1) the sale of minerals and/or mineral rights to related parties and (2) the purchase of various goods, services and assets from related parties. These transactions are common to most mining companies. The value of these transactions Based on the ongoing work on BEPS, the IGF (Intergovernmental Forum on Mining) and OECD has released guidance for source countries on transfer pricing in the mining sector. The transfer pricing and tax avoidance issues identified in the sector are 1. Excessive Interest Deductions

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Tax Solutions for Mining Taxation Services Deloitte

Tax Solutions for Mining Taxation Services Deloitte

Oct 25, 2018 Transfer Pricing in the Mining Industry 1. Excessive Interest Deductions Companies may use related-party debt to shift profit offshore via excessive interest... 2. Abusive Transfer Pricing Transfer pricing occurs when one company sells a good or service to another related company. 3. Undervaluation ... Transfer pricing is the mechanism by which prices are chosen to value transactions between related legal entities within the same multinational enterprise (MNE). These are referred to as controlled transactions and may include the purchase

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Transfer Pricing in Mining Workshop World Bank

Transfer Pricing in Mining Workshop World Bank

Mar 03, 2017 The mining sector is particularly susceptible to tax regulators scrutiny under the transfer pricing provisions because cross-border relationships and multi-jurisdictional activities are both necessary and common in this industry. Feb 13, 2018 Recent developments show that the GRA is currently implementing the transfer pricing regulations through conducting transfer pricing audit of some industries of which the extractive industry is included. As a member of the ATAF, it is expected that the GRA would tailor its approach to TP audits in the mining sector and intensify such audits.

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Toolkit on Comparability and Mineral Pricing OECD

Toolkit on Comparability and Mineral Pricing OECD

Since 2019, the OECD and others have worked with the Mongolian tax administration to strengthen revenue collection from the extractives sector. As a result of mining tax audit capacity-building initiatives, the Mongolian tax administration issued its first transfer pricing tax assessment in late 2020 for approximately U.S. $228 million and ... Mining Royalties - ISBN 0821365029 - World Bank . 20 Mining Royalties associated with mining and mineral commodities. ... 32 Mining Royalties Mineral sector investors will be ... transfer pricing tax ...

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New Toolkit Aims to Curb Transfer Mispricing in African Mining

New Toolkit Aims to Curb Transfer Mispricing in African Mining

Aug 26, 2018 The training aims to build the capacity of government officials in developing countries to identify and address transfer pricing risks within their mining sector and protect the mining tax base from abusive transfer pricing. Transfer Pricing Aspects of Possible Intercompany Transactions in the Oil Gas Industry 30 . Oil Gas Industry Customs Duties and Excise Duties in the EU 69 . Organizational Aspects of Transfer Pricing Transfer Pricing Control Framework 88 . A Global Transfer Pricing Policy 96

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The Mongolian Tax Administration partners with

The Mongolian Tax Administration partners with

May 08, 2013 Zambian officials have acknowledged that securing higher revenues from its mining sector, currently estimated to contribute between 9-10% Feb 17, 2020 Tax avoidance and illicit financial outflows in the extractive sector largely take place through transfer mispricing arrangements. In principle, transfer pricing is not bad in business, however, when it is used as an aggressive tax planning measure by manipulating the transfer price (mis-pricing) to achieve a tax benefit, it becomes problematic.

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Transfer Pricing in the Mining Sector

Transfer Pricing in the Mining Sector

In an ever-changing global economy, Transfer Pricing (TP) is one of the most important tax issues for multinational companies. With more than 3,000 professionals in over 80 countries, PwCs transfer pricing network of teams is well-positioned to advise you on a strategy that can help advance your goals within the ever-shifting compliance landscape. Sep 29, 2017 The Transfer Pricing Risk Assessment Tool is intended to be used primarily by tax authorities in resource-rich developing countries. It addresses the transfer mispricing challenge by offering user-friendly, step-by-step guidance on how to determine whether transactions in the extractive sector should be subject to transfer pricing audits.

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Transfer Pricing in the Mining Industry

Transfer Pricing in the Mining Industry

Transfer Pricing In The Mining Sector. Transfer pricing has emerged in the global economy as one of the most important tax issues for multinational companies.Transfer pricing is an important driver of shareholder value, providing an opportunity to optimise the value of a business by effective tax rate and foreign tax credit management. Transfer pricing in mining an african perspective im4dc.Implementation and application of transfer pricing legislation, and to fill some of the expertise gaps by focusing specifically on transfer pricing risks in the mining sector, with a specific focus on africa.For this study, key transfer pricing risks are being mapped with the objective.

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Transfer Pricing in the Mining Sector in Guinea

Transfer Pricing in the Mining Sector in Guinea

However, transfer pricing can become abusive when the related parties distort the price of a transaction outside an arms length value to make higher profits in lower-taxed jurisdictions and lower profits in higher-taxed ones, as a means of reducing the MNEs overall tax bill. There are two main transfer pricing risks in the mining sector ... What Mining Can Learn from Oil A Study of Special. However transfer pricing can become abusive when the related parties distort the price of a transaction outside an arms length value to make higher profits in lowertaxed jurisdictions and lower profits in highertaxed ones as a means of reducing the MNEs overall tax bill There are two main transfer pricing risks in the mining sector 1 ...

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