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Tax base erosion and profit shifting

Submit Comments on Two Draft Toolkits to Help Address Profit Shifting in Mining Sector

April 18, 2018

The IGF together with the OECD  invite comments on two draft toolkits that will help developing countries address profit shifting from their mining sectors via the undervaluation of mineral exports and excessive interest deductions.

For many resource-rich countries, including IGF members, 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. Two of the avenues for BEPS in the mining sector are excessive interest deductions, and undervaluation of mineral exports. IGF and the OECD are collaborating to develop BEPS guidance for governments and have prepared draft toolkits to address both issues.    

  1. Monitoring the Value of Mineral Exports: A Toolkit for Policymakers

This toolkit aims to help governments choose the appropriate policy option for monitoring the value of mineral exports, considering the type of mineral, the risk of undervaluation, existing government capacities, and available budget. Access the toolkit online.

  1. Limiting the Impact of Excessive Interest Deductions on Mining Revenues

This toolkit responds to a concern of many developing countries that multinational enterprises use debt “excessively” in mineral producing countries as a mechanism to shift profits abroad. Access the toolkit online.

Comments on both toolkits are invited from interested stakeholders by May 18, 2018. Comments should be sent by email to

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 Cooperation

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.

These draft toolkits are part of a series of products expected in 2018 and beyond. They reflect 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 organizations is available at: