I publish research, policy reports, and academic works, as well as practical toolkits, training materials, and guidance. I also record podcasts, which help to distil complex topics into plain English.
Natural Resource Governance Institute, 2016
This collection of work, consisting of a report and five country case studies, assesses the development and implementation of rules to monitor transfer pricing in the mining sector in Ghana, Guinea, Sierra Leone, Tanzania, and Zambia. The report sets out a number of recommendations that would help the five case study countries, as well as other countries in similar contexts, to better address transfer pricing risks in the mining sector through the application of the arm’s length principle, and alternative tax policy rules.
The report is also available in French here.
Listen to a podcast from the launch of my research at the Commonwealth Secretariat:
World Bank, 2017
Co-authors: Pietro Guj and Stephanie Martin
In 2015-16, the World Bank Group and the International Mining for Development Centre commissioned the Centre for Exploration Targeting to produce a reference guide for practitioners on transfer pricing and mining. This briefing note is a summary of the guide for policy makers.
South Africa, like other capital-importing countries, has lost tax revenue from multinational companies’ use of corporate debt financing: foreign companies lend to their South African subsidiaries and deduct interest rates from their taxable income in South Africa. In addition to the commonly used “debt-to-equity ratio” rule, which limits deduction of interests on debt when it represents more than 75 percent of a company’s capital, South Africa introduced an interest limitation rule in 2013. This rule limits the deduction of interests from related party debt to 40 percent of a company’s EBITDA. This case study analyzes how the rule has been implemented in South Africa and how much it helps the country address tax base erosion.
After a decade of private investment in the mining sector, the Tanzanian government reacted to persistently low revenue collection by investing resources in auditing capacity. It created the Tanzania Mineral Audit Agency, an autonomous agency, under the Ministry of Energy and Minerals in 2009. This case study analyzes the role, structure and composition of the agency, and discusses the outcomes in terms of revenue collection and government effectiveness.
In the 2000s, copper exports expanded in quantity and value, but income tax collected by Zambia’s revenue authority remained low. The revenue authority identified the discounted sale of minerals to affiliated companies abroad as a key factor behind this revenue loss. In 2008, the Ministry of Finance introduced a rule requiring mining companies to use publicly quoted benchmark prices as the basis for determining the transfer price of related party mineral sales. This case study analyzes how this rule, commonly referred to as the “sixth method,” was implemented in Zambia, the response from mining companies and whether the tax administration considers it a useful instrument.
Natural Resource Governance Institute, 2016
Since Ghana’s first large oil field began production in 2010, tax payments were lower than anticipated due to the deduction of development and exploration costs from neighboring extractive projects. The country has since revised the ring-fencing rules for both mining and petroleum operations, the results of which have yet to be seen. This case study considers the trade-offs associated with ring-fencing and explains why it should be approached with caution.
International Monetary Fund Podcasts, 2017
In this IMF podcast I explain why tax revenues from mining could be much higher if transfer pricing rules were enforced.
A Toolkit for Addressing Difficulties in Accessing Comparables Data for Transfer Pricing Analyses
The Toolkit refers to the OECD Mineral Product Pricing Guidance, which is a vital contribution to the knowledge base of resource-rich developing country tax authorities seeking to tackle underpricing of related party mineral sales. However, the Toolkit diminishes this practical contribution by reasserting the need for comparability adjustments to quoted prices (e.g. adjustments for quality, contractual terms, transportation, and insurance.) Read More.
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