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E-raamat: Mining Taxation: Reconciling the Interests of Government and Industry

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Mining Taxation: Reconciling the Interests of Government and IndustrySuurem pilt
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This book examines existing mineral fiscal policies covering income taxation, royalties, free carried and participative (community and government) interests and also highlights the impacts of these policies on the feasibility of mineral projects as well as on revenue and other benefits to the State. While publications already exist on the subject matter, they have invariably approached the topic primarily from a Government standpoint rather than the mining industry. This book aims to provide a balance in this debate by comparing the financial outcomes gained or foregone by both Government and industry under different policy regimes. The discussions are supported by quantitative examples to more clearly articulate the potential outcomes and better inform future fiscal policy decisions.
1 Introduction: Context, Objective and Outline of this Book
1(8)
1.1 Context: Mineral Policy and Governance in the Context of Mining Fiscal Regimes
1(4)
1.2 Objective: Informing and Improving the Government-Industry Tax Dialogue
5(1)
1.3 An Outline of the Book Content
6(3)
Reference
8(1)
2 Mining Taxation Principles and Objectives
9(20)
2.1 The Role and Contribution of Mining to the Economy, Mineral Policy and Governance
9(8)
2.2 Government's Fiscal Objectives versus Corporate Commercial Objectives
17(8)
2.2.1 Investment Attraction
19(1)
2.2.2 Economic Efficiency and Equity
20(2)
2.2.3 Revenue Maximisation and Stability and Sharing Benefits and Costs Between Industry and Government
22(2)
2.2.4 Transparency, Simplicity and Ease of Administration
24(1)
2.3 Reconciling Potentially Conflicting Government Objectives
25(4)
References
26(3)
3 Components of a Mining Taxation Package
29(14)
3.1 General Considerations
29(3)
3.2 Mineral Royalties
32(1)
3.3 Corporate Income Tax (CIT)
33(1)
3.4 Capital Gains Tax
34(1)
3.5 Withholding Taxes (WHT)
35(2)
3.6 Value-Added, Import-Export Taxes and Excises
37(1)
3.7 Quasi-Taxes
38(5)
References
41(2)
4 Different Types of Mineral Royalties
43(28)
4.1 General Principles
43(4)
4.2 Specific, Volume or Weight-Based Royalties
47(1)
4.3 Value-Based Royalties
47(7)
4.3.1 Determining the Value Base at Various Taxing Points Along the Value Chain
48(2)
4.3.2 Taxing Points Characteristics
50(4)
4.4 Profit-Based Royalties
54(3)
4.4.1 Sensitivity of Different Royalty Types to Changes in Commodity Prices: A Simple Comparative Example
54(1)
4.4.2 Hybrid and Multiple-Rates ad valorem Royalty
55(2)
4.5 Economic Rent Based Royalties
57(8)
4.5.1 General Background
57(1)
4.5.2 Resource-Rent-Based Royalties: The Australian MRRT Case
58(7)
4.6 Production Sharing Contract
65(1)
4.7 Concluding Remarks
66(5)
References
68(3)
5 Corporate Income Tax Provisions and Fiscal Incentives Specific to Mining
71(30)
5.1 General Considerations
71(2)
5.2 Fiscal Incentives as a Strategy to Attract Foreign Direct Investment (FDI)
73(2)
5.3 Fiscal Incentives for Mineral Exploration
75(6)
5.3.1 Mineral Exploration Incentive Schemes
75(2)
5.3.2 Flow Through Shares
77(2)
5.3.3 Tax Relief on Disposal of Exploration Tenements
79(2)
5.4 Capital Recovery Provisions
81(8)
5.4.1 Mining Capital Assets and Depreciation Methods
81(4)
5.4.2 Special Capital Recovery Provisions
85(4)
5.5 Tax Holidays
89(5)
5.5.1 General
89(1)
5.5.2 Time-Based Tax Holidays
90(2)
5.5.3 Tax Holidays Based on Quantity of Ore or Metal Extracted
92(1)
5.5.4 How to Avoid Tax Holiday Pitfalls
93(1)
5.6 Other Fiscal Incentives and Exemptions
94(7)
5.6.1 Exemption from Value-Added Tax (VAT)
94(1)
5.6.2 Exemption from Import-Export Custom Duties/Tariffs
95(1)
5.6.3 Rebates on Fuel and Other Excises
96(1)
5.6.4 Exemption from Withholding Taxes
97(3)
References
100(1)
6 Quantitative Financial Analysis of Impacts of Mineral Royalties on Project Economics and Resources Sterilisation: A Case Study
101(14)
6.1 Description of a Gold Mine Case Study and Analytical Methodology
101(3)
6.2 Impacts of a Specific or ad valorem Royalty at a Rate of 3.0%
104(1)
6.3 Impacts of a Specific or an ad valorem Royalty at a Rate of 7.0%
105(6)
6.3.1 Royalty Rate Ranges
106(2)
6.3.2 Impacts of Royalties Beyond Resource Sterilisation
108(3)
6.4 General Principles
111(4)
References
112(3)
7 Government Participation and Domestic Equity Requirements
115(28)
7.1 Participation Principles
115(1)
7.2 Free Carried Interest
116(4)
7.3 Impacts of a Non-Participative Interest
120(5)
7.4 Summary Results and Analysis
125(1)
7.5 The (Un)Sustainability of Local Participation
126(2)
7.6 Unencumbered Equity Ownership
128(15)
7.6.1 Potential Implications to Achieve Unencumbered Equity Ownership
128(1)
7.6.2 The General Regulations
128(1)
7.6.3 Quantifying a Group's Participation
129(3)
7.6.4 Projected Realised Equity Value from a Typical Group Investment in the Company
132(8)
7.6.5 Summary Comment
140(1)
References
141(2)
8 Stabilisation Agreements
143(10)
8.1 General
143(3)
8.2 Security of Tenure
146(2)
8.3 Transparent and Fixed Fiscal Goal Posts
148(1)
8.4 Purposes and impacts of Stabilisation Agreements
149(1)
8.5 Risk of Stabilisation Agreements Being Tampered With
149(4)
References
152(1)
9 Administering and Complying Fiscal Regimes in a Globalised Mining Industry
153(20)
9.1 Fiscal Policy, Legislative and Administrative Frameworks
153(3)
9.2 Mining as a Global Business
156(13)
9.2.1 Increasing Globalisation of the Mining Industry
156(1)
9.2.2 Taxation Issues Created by Globalisation of The Mining Industry
157(3)
9.2.3 Reform and Compliance Challenges in a Dynamic Taxation Environment
160(1)
9.2.4 Tax Minimising MNEs Structures and `Treaty Shopping'
161(1)
9.2.5 Issues Relating to the Determination of Appropriate Levels of Debt and Related Interest Rates
162(2)
9.2.6 Issues Relating to the Determination of Transfer Prices on the Provision of Goods and Services
164(3)
9.2.7 Disclosure, Documentation and Reporting in a Digital World
167(2)
9.3 Workable Solutions to Improve Mining Taxation Compliance and Administration
169(4)
References
171(2)
10 Discussion and Ideas
173(16)
10.1 Current State of Play: Comparing Different Mining Fiscal Regimes
173(6)
10.2 Major Trends in Mining Taxation Policy and Administration Development
179(10)
10.2.1 Mineral Production and Related Government Revenues Will Continue to Grow Because of Growth in Population and Per Capita Consumption
179(1)
10.2.2 Continuous Change and Instability in the Fiscal Regimes of Developing Countries
180(2)
10.2.3 Trends Towards Greater Harmonization of International Mining Tax Regimes
182(1)
10.2.4 Continuing Pressure for Greater Government and Local Participation in Mining Projects and for the Establishment of Downstream Processing Facilities in the Developing Countries Hosting the Mining Operations
183(1)
10.2.5 Tightening of International Tax Conventions and Rules to Combat Base Erosion and Profit Shifting (BEPS) and Increased Use of IT for Inter-Jurisdictional Tax Information Exchanges in Support of Audits
184(1)
10.2.6 Fiscal Challenges Created by the Increased Provision of Digitally Delivered Services Between Related Parties of MNEs
185(1)
10.2.7 Greater Community Involvement in Mining Tax Issues Affecting the Licence to Operate and Mining Companies' Reputational Damage
186(1)
10.2.8 Growing Impetus to Include Taxation of Carbon-Emission by Producers
187(2)
11 Ideas About the Way Forward
189(18)
11.1 General
189(2)
11.2 What Government Could Do
191(7)
11.2.1 Promoting Growth of the Mining Industry by Supporting Mineral Exploration
191(1)
11.2.2 Understand and Communicate Better with Industry
192(1)
11.2.3 Formulate and Implement Long-Term Mineral Resources Policy and Plans and Adopt Mining Fiscal Regimes that Balance Short and Long-Term Funding Needs
192(2)
11.2.4 Simplify Their Tax Packages and Cut `Red Tape' for Greater Clarity, Easier Administration and Lower Compliance Cost
194(2)
11.2.5 Adhere to Current International Tax Reform Initiatives Designed to Prevent Base Erosion and Profit Shifting (BEPS)
196(1)
11.2.6 Promote a More Harmonious Modus Operandi Viewing Mining Companies as Customers Not Adversaries
197(1)
11.2.7 Ensure Ready Access to and Availability of Key Officials to Provide Mining Companies with Relevant Advice and Prompt Decisions
198(1)
11.3 What the Mining Industry Could Do
198(5)
11.3.1 Carefully Analyse the Strength and Weaknesses of the Fiscal Regimes of Various Possible Investment Destinations Before Taking the Plunge
198(1)
11.3.2 More Effectively Communicate with Government Both Collectively and at the Individual Company Level to Inform and Influence Mining Fiscal Policy Formulation and Administration
199(1)
11.3.3 Engage as Far as Possible the Support of Local Communities Affected by the Project Through Local Employment and Procurement and Other Visible Socio-Economic Initiatives
200(1)
11.3.4 Improve the Realism of the Feasibility Studies and Promptly Inform Government of Any Significant Departure from the Initial Plan During Development and Subsequent Operations
201(1)
11.3.5 Establish a More Transparent and Cooperative Relationship with the Local Tax Authority by Being Upfront with Information Relevant to Potential Inquiries
201(1)
11.3.6 Accept that the BEPS Action Plans Have Now Been Accepted by a Majority of Jurisdictions and that Many Tax Benefits Derived from Artificial Global Structures and Liberal Interpretations of Transfer Prices Rules Are Rapidly Closing
202(1)
11.3.7 Behave in an Environmentally and Socially Responsible Manner
203(1)
11.4 Conclusive Remarks
203(4)
Appendices
207(18)
Appendix A Guiding Principles for Durable Extractive Contracts
207(2)
Appendix B Country Risk Classifications of the Participants to the Arrangement on Officially Supported Export Credits (Source OECD: http://www.oecd.org/trade/topics/export-credits/documents/cre-crccurrent-english.pdf)
209(5)
Appendix C Extract from ACIL Allen Consulting (2015) Economic Evaluation of the Exploration Incentive Scheme Offered by the Geological Survey of Western Australia
214(1)
Appendix D Cash Flow Model Summary
215(6)
Capital Expenditure and Depreciation Profile
218(2)
Cut-off Grade Calculations at Varying Royalty Rates
220(1)
Appendix E OECD Guidelines' Five Transfer Price Estimation Methods (Reproduced from Guj et al. 2017)
221(2)
Appendix F BEPS Action Plan
223(2)
Glossary 225
Dr Eric Lilford is a Senior Lecturer and researcher in the field of Mineral Economics, within the Western Australian School of Mines (WASM) in the Faculty of Minerals, Energy and Chemical Engineering at Curtin University. His interests lie in the analysis and quantification of the impacts that regulations and policies have on the development and sustainability of resources developments. Prior to his recent academic appointment at Curtin, Dr Lilford has held roles including being CEO or Executive of mining companies where he has negotiated, evaluated and managed the structuring and development of many different mining and exploration projects, for a variety of commodities, mostly across Africa. His engineering and mineral economics expertise are combined with his intimate understanding of the emerging market resources industry, from both the political and business viewpoints.

Dr Pietro Guj is a Research Professor at the Centre for Exploration Targeting, at the University of Western Australia and an Adjunct Professor in Mineral Economics at Curtin Universitys Graduate School of Business. These academic roles were preceded by a distinguished career in the exploration and mining industry, in Asia, Africa and Australia both in industry and Government. He held the role of Deputy Director General of the Department of Minerals and Energy and Executive Director of the Geological Survey of Western Australia after a few years as a finance executive for the Water Authority of WA. Dr Gujs main interests are in project evaluation, risk and decision analysis as applied to the mineral industry and in the formulation and administration of internationally competitive resources regulatory and fiscal regimes; fields in which he has lectured, published and consulted widely internationally. In recent years, Dr Guj has been retained by the World Bank to direct research and capacity building programs designed to improve mining taxation policy and administration frameworks. The most recent of these projects addressed the fiscal challenge of transfer pricing in the context of mineral-rich developing countries, with particular emphasis on Africa.  



Dr Lilford and Dr Guj are also members of a team that recently won the Australia Award Africa for the delivery of comprehensive intensive training programmes in Mineral and Energy Economics over the period 2018 - 2022.
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