Addressing BEPS Risks in the Extractives and Telecommunications Sectors
Extractives and Telecommunications sectors: The experience of developing countries and best practices to address BEPS risks based on audit cases and case law
23-25 October 2024 • 13:00-16:30 CEST
Organised by Tax Inspectors Without Borders (TIWB) Secretariat in partnership with the African Tax Administration Forum (ATAF)
and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF)
Virtual workshop
This virtual workshop will bring together senior level officials and experts from international organisations and tax administrations to address BEPS issues in the extractives and telecommunications sectors. Resource extraction and the telecommunications sectors fuel the global economy and play a strong economic role in many developing countries. These sectors have the potential to drive growth, development, and poverty reduction.
However, the tax bases in these sectors are subject to base erosion and profit shifting (BEPS) risks. Multinational enterprises (MNEs) can often shift their profits from the country hosting these sectorial activities to other, low-tax jurisdictions, which can have a negative impact on the domestic revenue mobilisation of the host country. Setting appropriate tax policies and ensuring the appropriate level of tax compliance in the extractives and telecommunications sectors require a combination of industry, tax policy, and tax compliance knowledge.
The event is open to tax officials and partners of the TIWB initiative. Participants are invited to register by or before Friday, 18 October 2024.
Day 1 – 23 October 2024 – BEPS issues in the extractives sector
13:00 – 13:10
- Opening remarks and overview of the importance of extractive industry taxation in resource-rich developing countries.
13:10 – 14:00
- Discussion on international tax and transfer pricing risks in the extractives sector. Topics include BEPS risks, the value chain, mineral valuation, and intra-group financing. Open discussion follows.
14:00 – 14:45
- Case Study 1: Transfer pricing implications of intra-group mineral sales, focusing on mineral pricing and valuation, presented by a representative from Nigeria's Federal Inland Revenue Service. Open discussion follows.
15:00 – 15:30
- Presentation on the impact of the OECD Two-Pillar Solution on the extractives sector, focusing on tax rules and incentives. Open discussion follows.
15:30 – 16:20
- Case Study 2: Tax challenges in mining and the oil and gas sectors in Mexico highlighting transfer pricing manipulation. Open discussion follows.
16:20 – 16:30
- Wrap up of Day 1 with a summary of discussions and closing remarks.
Day 2 – 24 October 2024 – BEPS issues in the extractives sector
13:00 – 13:10
- Opening remarks and summary of Day 1, highlighting key outcomes and welcoming participants to Day 2.
13:10 – 14:10
- Session on improving access to information to combat tax evasion in the extractives sector, discussing challenges with exchanging information across jurisdictions due to legal and legislative barriers.
14:10 – 15:10
- Case Study 3: Transfer pricing implications of intermediary companies offering procurement, management, and technical services in the oil sector in Armenia. Open discussion follows.
15:25 – 16:25
- Case Study 4: Transfer pricing risks associated with the sale of copper concentrate and domestic traders in Peru. Open discussion follows.
16:25 – 16:30
- Wrap up and closing remarks summarising Day 2’s discussions.
Day 3 - 25 October 2024 – BEPS issues in the telecommunications sector
13:00 – 13:30
- Overview of the economic importance of the telecommunications sector for developing countries, including emerging global tax issues such as revenue fraud, tax avoidance schemes by MNEs, and possible mitigating strategies.
13:30 – 14:30
- Case Study 1: Focus on transfer pricing risks associated with an MNE in the telecommunications sector in Seychelles. Open discussion follows.
14:50 – 15:50
- Case Study 2: Exploration of factors to consider when auditing an MNE in the telecommunications sector, benefits of the audit, and challenges faced by Ghana tax administration. Open discussion follows.
15:50 – 16:00
- Summary of the day’s discussions and closing remarks.
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