As part of the ongoing work of the OECD/IGF partnership on the BEPS in Mining Programme, the OECD and IGF are seeking public comments on a new toolkit designed to support developing countries in addressing the transfer pricing challenges faced when pricing minerals. This toolkit builds on Determining the Price of Minerals: A Transfer Pricing Framework and applies its transfer pricing principles specifically to the pricing of copper.
Determining the Price of Minerals: A transfer pricing framework for copper
- Submission period
- 10 July - 17 September 2025
About
Background
For many resource-rich developing countries, mineral resources present a significant economic opportunity to increase government revenue. Tax base erosion and profit shifting (BEPS), combined with gaps in the capabilities of tax authorities in developing countries, threaten this prospect. The OECD’s Centre for Tax Policy and Administration (CTPA) is collaborating with the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) to address some of the challenges developing countries face in raising revenue from their mining sectors. Under this partnership, a series of practice notes and tools are being developed for governments.
The IGF and OECD CTPA have formed a partnership, combining the IGF’s mining expertise with the OECD’s knowledge of taxation to design sector-specific guidance on some of the most pressing BEPS challenges facing resource-rich developing countries.
Government revenue depends on mineral products being priced and measured accurately. However, pricing is not always straightforward. It may be complicated by the different stages of mineral beneficiation, the lack of publicly quoted prices for certain minerals, and adjustments based on the quality or grade of the product. Many governments worry they do not know the value of their exported minerals and are therefore losing much-needed revenue.
How to contribute
A document is released for public consultation:
- Determining the Price of Minerals: A transfer pricing framework for copper (also available in French and Spanish) provides a framework to identify the primary economic factors that can influence the pricing of minerals (“mineral pricing framework”) using transfer pricing principles. It shows how the framework can be applied to copper. Further toolkits applying the framework to other commodities will be released as they are developed.
This toolkit is for policy makers and tax administrations in resource-rich developing countries where mining activity is being undertaken by multinational enterprises (MNEs). Mining provides a significant contribution to the economies of many developing countries; however, achieving an arm’s length price for the sale of the host state’s mineral products can be challenging. The cross-border sale and purchase of mineral products between related parties poses a significant BEPS risk through MNEs selling mineral products to related entities abroad at prices below arm’s length, thereby shifting sales revenue and profits offshore. The toolkit provides practical and meaningful guidance for developing countries to accurately delineate the transaction and price mineral sales on an arm’s length basis appliable to copper exports. The OECD and IGF are seeking comments regarding the application and usability of this toolkit to ensure that they are fit for purpose and appropriately tailored to the needs and requirements of developing countries.
Interested parties are invited to send their comments no later than 17 September 2025* by e-mail to CTP.BEPS@oecd.org in Word format (in order to facilitate their distribution to government officials). All comments should be addressed to the Global Relations and Development Division, OECD Centre for Tax Policy and Administration.
Please note that all comments received will be made publicly available. Comments submitted in the name of a collective "grouping" or "coalition", or by any person submitting comments on behalf of another person or group of persons, should identify all enterprises or individuals who are members of that collective group, or the person(s) on whose behalf the commentator(s) are acting.
* Deadline extended from 5 September 2025 to 17 September 2025.
Comments received
Published 2 October 2025
The OECD is grateful to the commentators for their input and has now published the public comments received.
- Download the comments (Zip file, 2 MB - Please open from a desktop computer)
Further information
Further information on the work of both organisations is available at:
