Transfer Pricing in Mining: an African Perspective

A briefing note.

By: Pietro Guj, Bryan Maybee, Frederick Cawood, Boubacar Bocoum, Joel Cooper, Nishana Gosai and Steef Huibregtse.

Reviews conducted by the World Bank Group (WBG) of the mining taxation policy and

administrative procedures of a number of mineral-rich African countries have identified

a strong need for a study focusing specifically on the administration of transfer pricing

in the African mining sector. The objective is to formulate a practical framework of

effective strategies for mineral rich developing countries in Africa to prioritise transfer

pricing audit efforts and concentrate resources and training toward the application of the

arm’s length principle to high-risk transactions in the sector. The study will also consider

the potential for application of various administrative tools, such as safe harbours and

advance pricing agreements. The results of the study will be published in 2015 jointly

by the WBG, the International Mining for Development Centre (IM4DC)2 and the Centre

for Exploration Targeting (CET)3 in the form of a source book that will provide practical

guidance on transfer pricing in the sector to tax practitioners in mineral-rich developing

countries in Africa and elsewhere.

Download the full article:

TP in Mining- An African Perspective.pdf

Download PDF • 609KB