Article seems a bit simplistic, but the issue of the mining code is real. e.g. transfer pricing not relevant to calculating royalty revenues. Mining execs clearly do care about fiscal regime. I don't know enough about new Mining Code itself - ask @ThomasLassourd @DavidManleyEcon
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Yes yes yes it's all very complicated but 1. If the difference between genuine losses and profit shifting is so fundamentally unknowable then the whole endeavour is meaningless and we might as well never speak of it again and ...
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... there's nothing wrong with taking an average over a heterogeneous population, nor can I believe you literary have no prior concerning the prevalence of bad practice.
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If you ask what is the prevalence of profit shifting, or at least overgenerous transfer pricing in a country that hasn't had the capacity to audit, I'd guess its very high - but it doesn't relate to yr 'zero profit years' test.
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So I don’t thinks it’s totally the wrong question but you need to know specifics - commodity, surface or underground etc - then you can look at cost profile of similar mines to see what’s reasonable.
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as mine gets older. But then commodity price volatility etc can push back into losses. And '0 tax bill' may not mean losses but result of carried interest as w Oyu Tolgoi