Mining Taxation: Reconciling the Interests of Government and Industry

ForewordAcknowledgementsPrecis1 Mineral Policy, Governance and its Economic Implications1.1 Government mineral and economic policy versus corporate financial objectives1.2 The concept of mineral economic rent1.3 Mining taxation principles and objectives1.4 Components of a mining taxation package1.5 Legislating for local participation: Participative and free-carry interests1.6 Trends in mining fiscal regime development 2 Quantitative Financial Analysis of Common Mining Taxation Instruments2.1 Analytical methodology2.2 Different types of mineral royalties and mining-specific corporate income tax provisions2.3 Royalties: Comparing the Government's and the Operator's position2.4 Government free carried interest: Analysing the benefits to Government and costs to industry2.5 Government participative interests: Comparing the Government's with the Operator's outcomes2.6 Analysing the revenue impact of fiscal incentives to attract investment2.7 Taxing instruments in petroleum fiscal regimes2.8 Discussion and ideas 3 Administering the Mining Fiscal Regime3.1 Main mining tax administration issues3.2 Mining as a global business3.3 Foreign investment attraction and fiscal incentives3.4 Stability agreements and sovereign risk minimisation3.5 Return on investment and repatriation of capital and profits3.6 Tax minimisation strategies through cross-border transactions between related parties: Transfer pricing, tax rate arbitrage, treaty shopping3.7 Withholding taxes and other Government defensive mechanisms3.8 Workable solutions to improve mining taxation collection and administration frameworks Conclusions and RecommendationsReferencesAppendices