This book presents the results of astudy on transfer pricing (TP) with specific focus on miningin Africa commissioned in early 2014 by the World Bank Group(WBG) in partnership with the International Mining forDevelopment Centre (IM4DC). The Source Book opens with theIntroductory chapter identifying the need for the study andthe way it was conducted. This is followed by the main bodyof the book that includes three parts. Part A (The miningindustry and transfer pricing) identifies what are the mostcommon transfer pricing issues in mining in general andwhere they are likely to occur along the mining value chain.Part B (The mining industry in Africa and transfer pricing)considers the same issues specifically in the context of themain commodities currently mined in Africa. This part andits related appendices provide a comprehensive inventory ofcurrent mining operations in Africa and information aboutthe revenue and cost structure of typical operations to helpestablish a methodology for the assessment andprioritization of transfer pricing risks, supported bypractical examples and case studies. Part C (Institutionaland administrative capacity) then relates to the question ofhow to prioritize and address the issues covered in Parts Aand B and discusses the resourcing, skills andorganizational structures necessary to ensure that the arm’slength principle is successfully abided to. The book closeswith a Discussion and Conclusions chapter which summarizesthe results of the study and the main strategies identifiedas appropriate to improve industry’s compliance with soundTP principles and the capacity of tax authorities to carryout an adequate level of effective TP auditing, thusminimizing revenue leakages. Relevant examples and casestudies are provided throughout the text in the form ofBoxes identifiable by a distinctive greenish-grey colored background.
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