OECD and IGF invite comments on a draft practice note that will help developing countries address profit shifting from their mining sectors via excessive interest deductions


28/05/2018 - The draft version of Limiting the Impact of Excessive Interest Deductions on Mining Revenues is now available for download in French. To give our colleagues who are more comfortable in this language a full opportunity to give us their feedback, we have extended the comment period to 15 June 2018.


18/04/2018 - For many resource-rich developing countries, mineral resources present an unparalleled 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. One of the avenues for international profit shifting by multinational enterprises is the use of excessive interest deductions.


Building on BEPS Action 4, this practice note has been prepared by the OECD Centre for Tax Policy and Administration under a programme of co-operation with the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF), to help guide tax officials on how to strengthen their defences against BEPS. It is part of wider efforts to address some of the challenges developing countries are facing in raising revenue from their mining sectors. This work also complements action by the Platform for Collaboration on Tax and others to produce toolkits on top priority tax issues facing developing countries.


Comments on the draft are invited from interested stakeholders by 18 May 2018 and should be sent by email to [email protected]. A version in French will also be released in the coming weeks.


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.

About the OECD-IGF Co-operation

The IGF and OECD Centre for Tax Policy and Administration have formed a partnership, combining the mining expertise of the IGF with the OECD’s knowledge of taxation, to design sector specific guidance on some of the most pressing base erosion challenges facing developing countries.


This practice note is part of a series of products expected in 2018 and beyond. It reflects a broad consensus between the OECD Centre for Tax Policy and Administration Secretariat and the IGF, but should not be regarded as the officially endorsed view of either organization or of their member countries.


Further information on the work of both organisations is available at:


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