Maya Forstater

Indeed I do. Apologies to Allie and Ali. Thanks

I think this article is a bit pessimistic - higher royalties should definitely increase gov't revenue collection, and potentially the profits tax too given cobalt prices have doubled in the last year.

...customer discounts may be included). My understanding is that royalties in Congo are calculated based on realised sale price minus costs. There is a publicly quoted price for cobalt, however I assume it is exported as copper-cobalt concentrate...

...so some kind of netback calculation must be required, not to mention treatment and refining, which if done by a related party smelter can create room for manipulation. So while transfer pricing issues more likely to be an issue for income tax, royalties may also be affected.

In terms of the transfer pricing issue, as @MForstater says this generally doesn't impact royalties as much as income tax, but it depends on how the royalty is computed, and to what extent costs incurred with related parties are eligible for deduction (e.g. in some countries...