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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. It 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.
Philip Daniel is Honorary Professor at the Centre for Energy, Petroleum and Minerals Law and Policy at the University of Dundee, UK, and Senior Fellow, Natural Resource Governance Institute. He served in the Fiscal Affairs Department of the IMF from 2006 to 2015.
Michael Keen is Deputy Director of the Fiscal Affairs Department of the International Monetary Fund. Before joining the Fund, he was Professor of Economics at the University of Essex, UK.
Artur Swistak is an economist in the Fiscal Affairs Department of the International Monetary Fund, where he works on tax policy issues. Prior to joining the IMF in 2011, he worked for the Polish Ministry of Finance as a chief of tax policy analysis division.
Victor Thuronyi is a graduate of Cambridge University and Harvard Law School. He has practiced tax law, served in the U.S. Treasury Department and taught tax law before joining the International Monetary Fund (1991-2014).
Preface
CHAPTER 1: Introduction and Overview
Philip Daniel, Michael Keen, Artur Swistak and Victor Thuronyi
CHAPTER 2: Principles and Practice of International Taxation for the Extractive Industries
Michael Keen and Peter Mullins
CHAPTER 3: An Overview of Transfer Pricing In Extractive Industries
Steven Shay
CHAPTER 4: Transfer Pricing - Special Extractive Industry Issues
Jack Calder
CHAPTER 5: International Tax and Treaty Strategy in Resource-Rich Developing Countries: Experience and Approaches
Philip Daniel and Victor Thuronyi
CHAPTER 6: Extractive Investments and Tax Treaties: Issues for Investors
Janine Juggins
CHAPTER 7: Taxing Gains on Transfer of Interest
Lee Burns, Honoré Le Leuch and Emil M. Sunley
CHAPTER 8: Fiscal Issues for Cross-border Natural Resource Projects
Joseph Bell and Jasmina Chauvin
CHAPTER 9: International Oil and Gas Pipelines: Legal, Tax, and Tariff Issues
Honore LeLeuch
CHAPTER 10: The Design of Joint Development Zones Treaties and International Unitizations Agreements
Peter Cameron
CHAPTER 11: Fiscal Schemes for Joint Development of Petroleum: A Primer and an Evaluation
Philip Daniel, Chandara Veung and Alistair Watson
CHAPTER 12: Taxes, Royalties and Cross-border Resource Investments
Jack Mintz
CHAPTER 13: Tax Competition and Coordination in Extractive Industries
Mario Mansour and Artur Swistak
