Transfer Pricing
In taxation and accounting, transfer pricing refers to the rules and methods for pricing transactions within and between enterprises under common ownership or control. Because of the potential for cross-border controlled transactions to distort taxable income, tax authorities in many countries can adjust intragroup transfer prices that differ from what would have been charged by unrelated enterprises dealing at arm’s length (the arm’s-length principle). The OECD and World Bank recommend intragroup pricing rules based on the arm’s-length principle, and 19 of the 20 members of the G20 have adopted similar measures through bilateral treaties and domestic legislation, regulations, or administrative …
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IISD: International Institute for Sustainable Development · 22 March 2024 English
Do policy-makers need to rethink fiscal policies to ensure the financial benefits from critical minerals are shared fairly?Are current fiscal approaches and policies aligned with national strategies, including ensuring that …
effect on government revenues; ⁰ a risk of transfer pricing abuse; and ⁰ artificially reduced taxable … determining the price of minerals using a transfer pricing framework, particularly for scenarios in … and royalties are calculated; • a risk of transfer pricing abuse—under-pricing specifically—if the mining …
AMC: Mining Association of Canada · 19 December 2023 English
Effective COI AAA ● Made enquiries and conducted interviews of Engagement and management of RDO to: Dialogue ○ Observe their understanding and implementation of policies and practices in place for …
Mining Principles. ensure and demonstrate that transfer pricing outcomes are in line with fair business practices … Implement processes to ensure and demonstrate that transfer pricing N/A - Not applicable as requirements outcomes …
AMC: Mining Association of Canada · 19 December 2023 English
Training Yes • Activation of the Suncor crisis and emergency preparedness and response plans has been demonstrated • Testing of the preparedness and response activities is occurring • Activation of …
Contributions 5. Transparency of Taxes, Ownership and Transfer Pricing 6. Accountabilities and Reporting 7. Engagement …
AMC: Mining Association of Canada · 18 December 2023 English
Summary of the The activities undertaken during the verification process are verification activities summarized below: • Prior to the verification, copies of the facility’s self-assessments and supporting documentation were made …
Contributions 5. Transparency of Taxes, Ownership and Transfer Pricing 6. Accountabilities and Reporting 7. Engagement …
AMC: Mining Association of Canada · 12 December 2023 English
Effective COI AAA ● Made enquiries and conducted interviews of Engagement and management of CdA: Dialogue ○ To observe their understanding and implementation of policies and practices in place for …
demonstrate Responsible Gold Mining Principles. that transfer pricing outcomes are in line with fair business practices … Implement processes to ensure and demonstrate that transfer pricing N/A - Not applicable as requirements outcomes …
AMC: Mining Association of Canada · 12 December 2023 English
● Obtained and inspected policies and management programs to review the alignment of policies and commitments with the MAC Safety and Health Framework. [...] ● Reviewed and inspected the programs …
annually website (partnerships) and within Transfer Pricing by country and Teck's sustainability report … Responsible Gold Mining Principles. demonstrate that transfer pricing outcomes are in line with fair business practices … Implement processes to ensure and demonstrate that transfer pricing N/A - Not applicable as requirements outcomes …
IISD: International Institute for Sustainable Development · 11 December 2023 English
A compendium of best practices for governments to manage the full range of issues in the mining sector.The Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development supports more than …
with tax treaty abuse, the manipulation of transfer pricing, and the taxation of offshore indirect transfers … international good practices in transfer pricing, such as the OECD or the UN Transfer pricing guidelines. • The tax … laws and regulations. º Undertake complex transfer pricing audits, which often require long and complex …
IISD: International Institute for Sustainable Development · 3 November 2023 French
frequency and scale of related-party transactions, the potential risk to tax revenues posed by transfer pricing non-compliance can be high, particularly around the value of the extracted minerals. …
titre Determining the Price of Minerals: A Transfer Pricing Framework for Bauxite © 2023 IISD/OECD. En …
IISD: International Institute for Sustainable Development · 3 November 2023 French
frequency and scale of related-party transactions, the potential risk to tax revenues posed by transfer pricing non-compliance can be high, particularly around the value of the extracted minerals. …
titre Determining the Price of Minerals: A Transfer Pricing Framework © 2023 IISD/OECD. En cas de divergence … 1401. The 6th method: Exploring the available transfer pricing methods, https://www.un.org/esa/ffd/wp-c … eports/ documentdetail/213881485941701316/transfer-pricing-in-mining-with-a-focus-on- africa-a-briefing-note …
IISD: International Institute for Sustainable Development · 3 November 2023 English
frequency and scale of related-party transactions, the potential risk to tax revenues posed by transfer pricing non-compliance can be high, particularly around the value of the extracted minerals. …
Determining the Price of Minerals A transfer pricing framework for bauxite BAUXITE © 2023 IISD/OECD … AUTHORS Andrew Viola is Senior Advisor, Transfer Pricing and Extractive Lead at the OECD. Thomas Lassourd … made by Vy Tran, formerly Senior advisor – Transfer Pricing and Extractive Lead, OECD and other colleagues … @OECD iii Determining the Price of Minerals: A transfer pricing framework for bauxite TABLE OF CONTENTS Introduction … 22 1 Determining the Price of Minerals: A transfer pricing framework for bauxite INTRODUCTION SCHEDULE …
