International - Income Taxation through the Life Cycle of an Extractive Industries Project

This article outlines the main income tax design issues arising during the life cycle of an extractive industries project, including upon exit from the project (the article expands upon the discussion of the income tax issues for extractives industries outlined in L. Burns, n. 3). While in many countries the significant involvement of non-resident investors in the sector means that international tax issues such as transfer pricing and thin capitalization are important, this article focuses primarily on domestic income tax issues.