Report

Determining the Price of Minerals: A transfer pricing framework

Practical guidance to support developing countries in accurately pricing mineral sales for the purposes of revenue collection.

By Andrew Viola, Alexandra Readhead on November 3, 2023

In the mining sector, royalties and corporate income taxes are generally based on the value of the mineral transacted. Consequently, it is critically important that any transactions involving the purchase and sale of minerals are valued correctly. Due to the frequency and scale of related-party transactions, the potential risk to tax revenues posed by transfer pricing non-compliance can be high, particularly around the value of the extracted minerals.

Determining the Price of Minerals: A Transfer Pricing Framework is a practice note providing practical and meaningful guidance for developing countries to accurately delineate the transaction and price of mineral sales to support revenue collection in the mining sector.

Focused price schedules for key minerals

Determining the Price of Minerals: A Transfer Pricing Framework for Bauxite provides a specific application of the framework for bauxite.

Determining the Price of Minerals: A Transfer Pricing Framework for Lithium provides a specific application of the framework for lithium.

Price schedules for copper and other minerals will be released gradually over time.

Report details

Topic
Mining
Project
The Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF)
Focus area
Resources
Economies
Publisher
IISD/OECD
Copyright
IISD/OECD, 2023