Business and Economics > Corporate Taxation

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Ms. Giorgia Albertin
,
Boriana Yontcheva
,
Dan Devlin
,
Hilary Devine
,
Mr. Marc Gerard
,
Sebastian Beer
,
Irena Jankulov Suljagic
, and
Mr. Vimal V Thakoor
This paper aims to contribute to the international policy debate around profit shifting, tax avoidance and SSA’s revenue mobilization efforts in three ways. First, it examines the importance of mining, the role of multinational enterprises (MNEs), and mining revenue outcomes in SSA. Second, it assesses the magnitude of profit shifting in mining drawing on new macro level research, supplemented by case studies to illustrate the lived experience of tax avoidance in SSA mining. Third, the paper identifies tax policy reforms that could boost revenue mobilization in SSA.
Sebastian Beer
Profit shifting remains a key concern in international tax system debate, but discussions are largely based on aggregate estimates, with less attention paid to individual sectors. Drawing on a novel dataset, we quantify tax avoidance risks in the extractive industries, a sector which is revenue critical for many developing economies. We find that a one percentage point increase in the domestic corporate tax rate has historically reduced sectoral profits by slightly over 3 percent; and the response tends to be more pronounced among mining than among hydrocarbon firms. There is only weak evidence transfer pricing rules contain tax minimization efforts of MNEs in our sample, but interest limitation rules (e.g., thin capitalization or earnings based rules) do reduce the observable extent of profit shifting. Our findings highlight the challenge of taxing income in the natural resource sector and suggest how fiscal regime design might be strengthened.
International Monetary Fund. Fiscal Affairs Dept.
This paper discusses Malian mining taxation. Mali’s industrial mining sector is predominantly gold mining, with six industrial mines currently active. Most of the mines are old, but some have substantial reserves; extensions are planned for the Syama, Morila, Kalama, Tabakoto-Segela, and Loulo-Gounkoto mines. The Fiscal Analysis for Resource Industries model was completed for five new projects with recent feasibility studies. The government revenue contributed by the five new projects is on the order of US$1.7 billion (constant dollars) over the next 10 years. The application of the 1999 or 2012 Mining Code increases the government’s share of income in comparison with the 1991 code.
International Monetary Fund. Fiscal Affairs Dept.
La plupart des mines sont anciennes mais leurs réserves en minerai demeure importantes pour certaines d’entre-elles. Ainsi des extensions sont envisagées pour les mines de Syama, Morila, Kalama, Tabakoto-Segela et Loulo-Gounkoto. Une mine, Robex, devrait entrer en production prochainement et une étude de faisabilité a été déposée pour la mine de Fekola. Les aménagements de la mine de Kodiéran, détenue par Wassoul’or, pourraient reprendre au cours de l’année 2015, suite au versement de plus de 7 milliards de FCFA aux différents créanciers. Ainsi, la tendance baissière de la production d’or au Mali pourrait s’inverser durablement dans les prochaines années si le prix du marché mondial demeurerait à son niveau actuel.
International Monetary Fund. Fiscal Affairs Dept.
EXECUTIVE SUMMARY This report is provided to support the work of the ‘Sheshinski II’ committee in reviewing the fiscal regime for mining. Mining is, and will remain, relatively minor both as a source of government revenue and within the wider economy. Nonetheless, it is important that the fiscal regime deliver to the public an appropriate share of the return to the exploitation of resources that they own while also providing investors with a sufficiently attractive and stable environment. To that end, this report reviews principles, experience and tools in mining taxation, bringing them to bear on the analysis of, and suggesting potential improvements to, the current regime. The current use of royalties as the sole and in some cases quite burdensome special fiscal instrument for mining is problematic. One of the primary benefits of royalties—that they ensure some revenue from the start of production—is of limited relevance in Israel, where production is highly mature and exploration minimal. More to the fore is their ineffectiveness in achieving one of the primary goals that warrants a special fiscal regime in the extractive industries: the prospect of designing a charge on rents—returns, that is, in excess of the minimum required by the investor—that can raise revenue without distorting commercial decisions. Their insensitivity to profitability means that royalties not only fail to do this, but, perversely, imply that the government actually takes a smaller share of rents when commodity prices are high; and, conversely, that the company faces a very high effective tax on its profits when those profits are low. Simulations reported here show that these undesirable effects are very marked under the current fiscal regimes. Indeed cutting top marginal royalties-even in the absence of any other reform—would in some cases almost certainly increase both government revenue and after-tax profits. Alternative fiscal regimes—combining a modest mineral-specific royalty with a common profit-based tax—would resolve this structural weakness. The focus of the report is not on the level of the ‘government take’ from minerals—ultimately a political choice—but on how that take varies with the profitability of the underlying investment. To that end, it reports illustrative simulations (for a hypothetical but not unrealistic project) of alternative fiscal regimes that imply the same government take in a benchmark case but respond very different to project profitability. These alternatives combine a relatively low royalty—which may have some merit in protecting the base against tax avoidance through cost manipulation—with four alternative forms of profit-based tax (retaining, in all but one, the current corporate income tax); and consider too the possibility of converting the royalty into, in effect, prepayment of a profit-based tax. These options differ in important ways—in the required statutory rate of the profit tax, transitional issues, and the time path of government revenues. But they all address the key structural problem, providing structures in which the effective tax rate is lower, not higher, for less profitable outcomes. Fiscal regimes of broadly this kind are (increasingly) commonplace in mining, including in major mineral producing countries. The treatment they provide would be similar to, but could be simpler than, that adopted for oil and gas following ‘Sheshinski I.’
International Monetary Fund
Better designed and implemented fiscal regimes for oil, gas, and mining can make a substantial contribution to the revenue needs of many developing countries while ensuring an attractive return for investors, according to a new policy paper from the International Monetary Fund. Revenues from extractive industries (EIs) have major macroeconomic implications. The EIs account for over half of government revenues in many petroleum-rich countries, and for over 20 percent in mining countries. About one-third of IMF member countries find (or could find) resource revenues “macro-critical” – especially with large numbers of recent new discoveries and planned oil, gas, and mining developments. IMF policy advice and technical assistance in the field has massively expanded in recent years – driven by demand from member countries and supported by increased donor finance. The paper sets out the analytical framework underpinning, and key elements of, the country-specific advice given. Also available in Arabic: ????? ??????? ?????? ???????? ???????????: ??????? ???????? Also available in French: Régimes fiscaux des industries extractives: conception et application Also available in Spanish: Regímenes fiscales de las industrias extractivas: Diseño y aplicación
International Monetary Fund
This Technical Assistance (TA) Report on the Philippines discusses the fiscal regime for the mining sector. The Philippines has long been a producer of minerals, but the mining and petroleum sectors account for only a small share of the economy, exports, and government revenue. The petroleum sector comprises only two fields—one producing natural gas and condensate and one producing crude oil. The TA report suggests legislative reforms of financial and technical assistance agreements (FTAAs), repealing of tax incentives and consolidating all domestic tax rules, and fostering sound environmental practices.
International Monetary Fund
This paper examines and tests the existence of political budget cycles in Papua New Guinea during the period 1988–2004. Several factors point to the existence of political budget cycles in Papua New Guinea. The paper provides an overview of the political business cycle literature, and Papua New Guinea’s political structure and processes. It also describes the data set and the empirical methods used to test for the presence of election-influenced spending, and presents the results of a time-series analysis.