The taxation of extractive industries exploiting oil, gas, or minerals is usually treated as a sovereign, national policy and administration issue. This book offers a uniquely comprehensive overview of the theory and practice involved in designing policies on the international aspects of fiscal regimes for these industries, with a particular focus on developing and emerging economies.
International Taxation and the Extractive Industries addresses key topics that are not frequently covered in the literature, such as the geo-political implications of cross-border pipelines and the legal implications of mining contracts and regional financial obligations. The contributors, all of whom are leading researchers with experience of working with governments and companies on these issues, present an authoritative collection of chapters. The volume reviews international tax rules, covering both developments in the G20-OECD project on ’Base Erosion and Profit Shifting’ and more radical proposals, identifying core challenges in the extractives sector.
This book should become a core resource for both scholars and practitioners. It will also appeal to those interested in international tax issues more widely and those who study environmental economics, macroeconomics and development economics.
Table of Contents
CHAPTER 1: Introduction and Overview
(Philip Daniel, Michael Keen, Artur Swistak and Victor Thuronyi)
CHAPTER 2: Principles and Practice of International Taxation for the Extractive Industries
(Michael Keen and Peter Mullins)
CHAPTER 3: An Overview of Transfer Pricing In Extractive Industries
(Stephen E. Shay)
CHAPTER 4: Transfer Pricing – Special Extractive Industry Issues
CHAPTER 5: International Tax and Treaty Strategy in Resource–Rich Developing Countries: Experience and Approaches
(Philip Daniel and Victor Thuronyi)
CHAPTER 6: Extractive Investments and Tax Treaties: Issues for Investors
CHAPTER 7: Taxing Gains on Transfer of Interest
(Lee Burns, Honoré Le Leuch and Emil M. Sunley)
CHAPTER 8: Fiscal Issues for Cross-border Natural Resource Projects
(Joseph C. Bell and Jasmina B. Chauvin)
CHAPTER 9: International Oil and Gas Pipelines: Legal, Tax, and Tariff Issues
(Honoré Le Leuch)
CHAPTER 10: The Design of Joint Development Zones Treaties and International Unitization Agreements
CHAPTER 11: Fiscal Schemes for Joint Development of Petroleum: A Primer and an Evaluation
(Philip Daniel, Chandara Veung and Alistair Watson)
CHAPTER 12: Taxes, Royalties and Cross-border Resource Investments
CHAPTER 13: Tax Competition and Coordination in Extractive Industries
(Mario Mansour and Artur Swistak)
Philip Daniel is Honorary Professor at the Centre for Energy, Petroleum and Minerals Law and Policy at the University of Dundee, UK, and Senior Fellow, Natural Resource Governance Institute. He served in the Fiscal Affairs Department of the IMF from 2006 to 2015.
Michael Keen is Deputy Director of the Fiscal Affairs Department of the International Monetary Fund. Before joining the Fund, he was Professor of Economics at the University of Essex, UK.
Artur Świstak is an economist in the Fiscal Affairs Department of the International Monetary Fund, where he works on tax policy issues. Prior to joining the IMF in 2011, he worked for the Polish Ministry of Finance as a chief of tax policy analysis division.
Victor Thuronyi is a graduate of Cambridge University and Harvard Law School. He has practiced tax law, served in the U.S. Treasury Department and taught tax law before joining the International Monetary Fund (1991–2014).