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Base Erosion and Profit Shifting

IGF Guidance for Governments: Base erosion and profit shifting is a combination of policy and administrative tools meant to equip developing country governments with the knowledge, skills and tools to build and administer mining tax systems robust enough to address tax base erosion and profit shifting (BEPS) to improve domestic revenue mobilization and enable countries to fully implement the Sustainable Development Goals (SDGs).

Read the full workplan

Why Is IGF Working on BEPS?

The International Monetary Fund (IMF) estimates developing countries’ BEPS revenue losses exceed USD 200 billion annually, across all sectors. With a long list of SDGs to finance, and the end of the commodities super cycle, it is more important than ever that resource-rich developing country governments ensure existing mining projects contribute their full share to government budgets.

This is why IGF has partnered with the Organisation for Economic Co-operation and Development (OECD) Centre for Tax Policy and Administration to provide IGF members with guidance documents to help navigate this complex topic. Together, we are combining IGF’s mining expertise with the OECD’s knowledge of taxation to design sector-specific solutions to some of the most pressing base erosion challenges facing developing countries.

Meeting the Challenges

Over 100 countries are working together to address BEPS through the G20/OECD BEOS initiative. This inclusive framework aims to address significant gaps in existing national and international tax rules exploited by multinational corporations.

IGF’s guidance for governments on addressing BEPS in the mining sector builds on this program. IGF will cover the following issues: excessive interest deductions; transfer mispricing; undervaluation of mineral exports; harmful tax incentives; tax stabilization; international tax treaties; indirect transfer of mining assets; metals streaming; abusive hedging arrangements; and inadequate ring-fencing.

Guiding Principles

IGF is working to develop a combination of policy and administrative tools for use by resource-rich developing country governments for each of the 10 issues listed above. The precise nature of these products will vary from issue to issue depending on need, as well as work being done by other international and non-governmental organizations. However, there are three overarching principles which guide this work:

  1. Adapt existing guidance on international tax issues to be mining-sector specific. We are taking tax issues experienced by a range of sectors in the economy (such as double taxation treaties) and developing a framework by which governments of resource-rich countries can analyze the impact of treaty provisions on taxes imposed on the mining sector, as well as possible strategies to protect the mining tax base against specific treaty risks.
  2. Fill vital gaps in the available resources. We are developing new practical guidance and tools that specify the precise legal, administrative, organizational and technical means required for tax authorities and mining regulatory agencies to address the tax issue. For example, we look at “metals streaming,” a financing arrangement that may reduce the tax base of resource-producing countries, for which there is virtually no guidance.
  3. Keep administrative capacity front of mind. We are delivering practical tools capable of being implemented by developing country tax authorities. Mining tax law is only as effective as the administrative capacity of the tax authority responsible for enforcing it. Developing country tax authorities face a range of challenges that impede tax administration, including limited resources, technical expertise and access to tax information. All products will be designed to address these specific challenges.

Managing Transfer Pricing Risk Assessment in the Mining Industry

IGF is providing training to help African tax authorities address transfer mispricing in the mining sector.
This training is based on a new toolkit aimed at helping African tax authorities address transfer mispricing in the mining sector published by the African Tax Administration Forum (ATAF) with Deutsche Gesellschaft für Internationale Zusammenarbeit GmbH (GIZ).

The Toolkit for Transfer Pricing Risk Assessment for the African Mining Industry helps to determine whether particular high-risk, related-party transactions should be selected for a transfer pricing audit. IGF was invited to be the toolkit’s official training partner.

Our Experts

Dan Devlin is the Senior Economist in Natural Resource Taxation at the OECD. He is also a technical adviser to the OECD-UNDP Tax Inspectors Without Borders project on mining in Liberia.

Howard Mann is an Associate & Senior International Law Advisor to IISD and IGF. He is a specialist in international investment and sustainable development law, as well as mining contract negotiations.

Alexandra Readhead is Technical Advisor to the IGF on Tax Base Erosion and Profit Shifting. She is a specialist in international taxation and the extractive industries.

Get Involved

We recognize there are many governments, organizations and individuals with significant expertise in mineral tax policy and administration, and we are keen to leverage this wherever possible. Current collaborators include: the African Development Bank, the African Mining for Development Centre, the International Council on Mining and Minerals, the International Monetary Fund, the International Senior Lawyers Project, United Nations Tax Committee and the World Bank Group.

Please contact us at if you or your organization would like to know more about the program, have something to contribute or if you have suggestions for us.


The program has initial funding from Deutsche Gesellschaft für Internationale Zusammenarbeit GmbH (GIZ) and the Canadian government, with additional funding provided by the Australian government.

More funds are still required.

If your organization is interested in helping fund the IGF BEPS in Mining Program, please contact Alexandra Readhead at or Howard Mann at