Global relations and development

OECD and IGF invite public comments on draft toolkits to support developing countries in addressing base erosion and profit shifting risks when pricing minerals


10/05/2023 - As part of the ongoing work of the OECD/IGF partnership on base erosion and profit shifting (BEPS) in the mining programme, the OECD and IGF are seeking public comments on two toolkits. The first toolkit provides a framework that is designed to support developing countries in addressing the transfer pricing challenges faced when pricing minerals. The second toolkit applies this transfer pricing framework to a specific mineral (bauxite).



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 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 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. This guidance reflects a broad consensus between the OECD Secretariat and the IGF, but should not be regarded as the officially endorsed view of either organisation or of their member 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. This practice note aims to increase policy-makers' knowledge of the process of determining the price of exported minerals.


Public consultation documents

Two documents are released for public consultation:


These toolkits are for policy-makers and tax administrations in resource-rich developing countries where mining activity is being undertaken by multinational enterprises (MNE's). 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—generally to a low tax jurisdiction. The toolkits provide practical and meaningful guidance for developing countries to accurately delineate the transaction and price mineral sales on an arm's length basis. The OECD and IGF are seeking comments regarding the application and usability of the toolkits 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 separately on each of these documents no later than 14 July 2023 by e-mail to [email protected] 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.


More information

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