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.




content


1 Introduction and overview 1
PHILIP DANIEL, MICHAEL KEEN, ARTUR ŚWISTAK
AND VICTOR THURONYI
2 International corporate taxation and the extractive
industries: principles, practice, problems 11
MICHAEL KEEN AND PETER MULLINS
3 An overview of transfer pricing in extractive industries 42
STEPHEN E. SHAY
4 Transfer pricing – special extractive industry issues 79
JACK CALDER
5 International tax and treaty strategy in resource–rich
developing countries: experience and approaches 111
PHILIP DANIEL AND VICTOR THURONYI
6 Extractive investments and tax treaties: issues
for investors 133
JANINE JUGGINS
7 Taxing gains on transfer of interest 160
LEE BURNS, HONORé LE LEUCH AND EMIL M. SUNLEY
8 Fiscal issues for cross-border natural resource projects 190
JOSEPH C. BELL AND JASMINA B. CHAUVIN

9 International oil and gas pipelines: legal, tax, and
tariff issues 215
HONORé LE LEUCH
10 The design of joint development zone treaties and
international unitization agreements 242
PETER CAMERON
11 Fiscal schemes for joint development of petroleum in
disputed areas: a primer and an evaluation 264
PHILIP DANIEL, CHANDARA VEUNG AND ALISTAIR WATSON
12 Taxes, royalties and cross-border resource investments 306
JACK M. MINTZ
13 Tax competition and coordination in extractive
industries 332
MARIO MANSOUR AND ARTUR ŚWISTAK
Index 359