
The Tax Programme of the OECD Korea Policy Centre has
held the 103rd tax seminar regarding ‘Comparability Analysis in
Transfer Pricing, with focus on the Mining Industry’ from September 18th to 23rd in Seoul and Pohang.


For this seminar, two
experts from the OECD have joined the event to provide lectures and discuss matters related to tax issues in mining industry. Also, around 20 participants from Asia
Pacific countries such as China, Vietnam, and Thailand have come to the seminar
and actively involved in the event by sharing their experiences, policies and
technical tools in transfer pricing issues in mining industry.


The seminar has mainly considered about how to
improve understanding of the mines operating in the borders and how countries
can go for verifying the prices of mineral products are sold to related
parties.
Also, this workshop has examined several case
studies on main mineral such as old, copper, iron ore, thermal coal and rough
diamonds – and provided participants with discussion about how to get clear
understanding of mining sectors through a combination of better information and
potential avenues to resolving information gaps.

The topics covered include:
ㅁ Issues
Arising when Conducting a Comparability Analysis, including:
o
Delineating
the transaction between related parties
o
Data
for comparability analyses and making optimal use of available data
o
Determination
of and making comparability adjustments where appropriate
o
Interpretation
and use of data collected, determination of the arm’s length remuneration
ㅁ Approaches
to Applying Internationally Accepted Principles in the Absence of Comparables
ㅁ Understanding
the mining industry and how minerals are priced, including case studies into iron
ore; copper; gold; thermal coal; and rough diamonds

After the seminar, participants have visited POSCO
steel located in Pohang for the field trip to get better understanding of the issues by observing the steel making process and use of mineral products.