As part of the ongoing work of the OECD and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) partnership on BEPS in the mining programme, the OECD has released an additional toolkit that is designed to support developing countries in addressing the transfer pricing challenges faced when pricing minerals for comments.


On November 6, 2023 the document; “Determining the Price of Minerals: Application to Lithium” was released for public consultation. The document provides a framework to identify the primary economic factors that can influence the pricing of minerals ("mineral pricing framework") using transfer pricing principles. It shows how the framework can be applied to lithium. Further toolkits applying the framework to other commodities will be released as they are developed.


This toolkit is meant for policymakers and tax administrations in resource-rich developing countries where mining activity is being undertaken by multinational enterprises (MNEs). Mining provides a significant contribution to the economies of many developing countries; however, achieving an arm's length price for the sale of the host state's mineral products can be challenging. The cross-border sale and purchase of mineral products between related parties poses a significant BEPS risk through MNEs selling mineral products to related entities abroad at prices below arm's length, thereby shifting sales revenue and profits offshore. The toolkit provides practical and meaningful guidance for developing countries to accurately delineate the transaction and price mineral sales on an arm's length basis applicable to lithium exports. The OECD and IGF are seeking comments regarding the application and usability of this toolkit to ensure that they are fit for purpose and appropriately tailored to the needs and requirements of developing countries.


The OECD states that interested parties are invited to send their comments no later than February 2, 2024 by e-mail to This email address is being protected from spambots. You need JavaScript enabled to view it. in Word format (in order to facilitate their distribution to government officials). All comments should be addressed to the Global Relations and Development Division, OECD Centre for Tax Policy and Administration.


Please note that all comments received will be made publicly available. Comments submitted in the name of a collective "grouping" or "coalition", or by any person submitting comments on behalf of another person or group of persons, should identify all enterprises or individuals who are members of that collective group, or the person(s) on whose behalf the commentator(s) are acting.



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