Overview
Owing to the unique character of minerals as commodities, the area of transfer pricing in the mining sector is highly intricate. As multinational enterprises (MNEs) operate in a variety of jurisdictions, the price of such nonrenewable resources has a significant impact on fiscal revenues in resource-rich countries.
This significance is seen in the implementation of the so-called “Sixth Method” in a number of jurisdictions, including Zambia. The Sixth Method is an alternative approach to transfer pricing aimed at ensuring a fair taxation environment for mineral transactions.
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