The Fiscal Terms and Resource
Revenue Collection
1- Why does extractive industry require a special taxation regime?
2- What is this special taxation system?
3- Why do we need progressive fiscal regime?
4- Why can we speak about a mirage regarding locally-held equity ?
5- Capital Gains Tax: What is challenging about it ?
6- Do low income countries need tax incentives to attract investment?
7- What is the importance of fiscal modeling for host countries?
8- What are the main challenges of fiscal regime design ?
Stylized Mining and Gas Project Timeline
Revenue
Capital Costs
Operating Costs
Exploration Costs
Project Timeline 
Source: Revenue Watch Institute
Stylized Oil Project Timeline
Source: Revenue Watch Institute
Oil depleted faster than minerals, payback period is shorter, opex over the life
of the project lower -> more profitable than mining , generally speaking
High Potential For Increase In “Rent”
“RENT” or
“SUPER/EXCESS
PROFIT”
Stylized Project
Breakdown
Total
Costs
Minimum
Return
Rent
Source: Revenue Watch Institute
Extractive Industry: A Specific Sector With a
Specific Tax Policy
Why is Extractive Industry specific ?
Calls for a resource specific taxation
• Lengthy exploration period with no
revenue
• Special Tax Treatments to encourage
exploration - always demanded and
considered justified by companies
• High Capital expenditure making the
capital captive and not transportable
• High probability of social and
environmental damage
• Cyclical revenues because of volatile
commodity market
• Minerals are finite and belong to the
State or the land owner
• Long life of mine implies potential for
regime changes and policy instability
•Tremendous potential for high “rent”
(Financial returns above those a company
requires to invest ). The rent increases with
the quality of the mineral deposit
•Use of taxation incentives for investment
in communities and protection of the
environment
• Request for use of profit-based taxes by
the investors
• Royalty: price of the right to use the
land belonging to either the national state
/ local government or the landowners
(US) + immediate revenues
•Need of a progressive fiscal regime that
self-adjusts to circumstances and
profitability to ensure stability of the
system
1- Why does extractive industry require a special taxation regime?
2- What is this special taxation system?
3- Why do we need progressive fiscal regime?
4- Why can we speak about a mirage regarding locally held equity ?
5- Capital Gains Tax: What is challenging about it ?
6- Do low income countries need tax incentives to attract investment?
7- What is the importance of fiscal modeling for host countries?
8- What are the main challenges of fiscal design ?
Main Types of Tax Instruments

Royalty
•
•

Corporate Income Tax
Imposed on value of mineral sales (ad valorem) or on
production volume (unit based).
The value can be defined in different maners (FOB, CIF,
mine – gate, netback )
•
Most states apply a standard national corporate
rate in the range of 20% to 35% of profits

Investment Credit/
Capital allowance
•
A percentage of the capital expenditure that is tax
deductible

Loss and Carry
Forward
•
An accounting technique that applies the current
year's net operating losses to future years' profits in
order to reduce tax liability

Depreciation and
Amortization (D&A)
•
Accounting mechanism to spread out the capital
expenditure over many years-> tax deductible and
investment incentive
•
On Dividends for foreign shareholders- common
and encourage re-investment in the country
 Withholding Tax on
Dividends
Elements of Fiscal instruments
1.
2.
3.
The Rate:

5% royalty

30% income tax rate

10% equity share
Room for
manipulation
The Base

The number against which the rate is applied.

Revenue-based? Production – Based? Profit - Based?

Need of a clear definition : gross revenue? Net revenues? Profit including
depreciations? Before depreciation?
Timing
 For developing countries funding growth and development, timing matters.
 Timing also relates to the risk of different revenue streams.
Room for
political economy
Importance of the Tax Base!
How to manipulate the royalty base?
- Royalty Rate of 3% for Copper
- Copper Sold at Export Point at $7500/Ton
- Transport and Processing Costs of $500/Ton
Royalty per Ton under Net Back
= rate * (gross – costs)
= 3% * (7500 – 500)
= 3% * 7000
= $210
Royalty per Ton under Gross
= rate * gross
= 3% * 7500
= $225
Room for
manipulation
Complexity of the Definition of the Tax Base
Source: World Bank
Complexity of the Definition of the Tax Base
Yes
No
No
Is taxing point at
mine gate?
Yes
Deduct Allowable
Processing Costs
Is taxing point FOB
port of export?
Use Gross Realized
Value as per Invoice
Deduct Allowable
Export, Sea Freight
and Marine
Insurance Costs
CIF
Mine gate
FOB
Legend:
Start of process
Deduct Allowable
Domes c and Export
Transporta on Costs
Decision point
Task
Fiscal Instruments – A Common Example In
Extractive Industries
Gross Revenue From Oil, Gas or Mining (P*Q)
Gross Revenue To Investor
Production
Cost – “OPEX”
Pre- Tax Profit (EBT)
Profit Tax
After-Tax Profit
Includes financial cost
and depreciations
Royalty
Dividends
Reserves
Inv.’s
Dividend
W/H Govt.
tax Equity
[W/H = withholding]
Investor Return
Source: Revenue Watch Institute
Government Revenue
Fiscal Regime in the Oil Sector is often
Different from Mining
Mining mostly here
Profit Sharing – How Does It Work ?
In PSC, contractor
receives a share of
the proceeds from
Cost Recovery and
Profit Split
In PSC, government receives a
share of the proceeds from
Profit Split and taxes paid by
the contractor on its take
PSCs have never taken off in the mining sector … why?
1- Why does extractive industry require a special taxation regime?
2- What is this special taxation system?
3- Why do we need progressive fiscal regime?
5- Capital Gains Tax: What is challenging about it ?
6- Do low income countries need tax incentives to attract investment?
7- What is the importance of fiscal modeling for host countries?
8- What are the main challenges of fiscal regime design ?
Fiscal Regimes Are Assessed Against 2 Main Indicators Revealed
by the Fiscal Model
Effective Tax Rate (ETR)
Internal Rate of Return (IRR)
Definition:
Total government taxes
ETR= Cumulative Pre-tax profit
Definition : Makes the positive cash
flows (project revenues) equal to
negative cash flows (initial investments)
- Must be above the cost of capital
Comparing the fiscal regimes based on
this ETR in a selection of countries that
compete for mining investment (“peer
countries”) helps assess the fairness FOR
BOTH PARTIES of the fiscal regime
- The higher the better!
- Can be used to rank several prospective
projects a firm is considering.
- Can be increased by leverage hence the
interest of thin capitalization
Assess what is called the
Government Take in the
project
Assess the profitability of the
project
When commodity prices go up and/ or project costs
go down, everybody benefits, but the percentages may
change.
Low Oil Prices
or High Cost
situation
Contractor
Total Net Profit
Contractor Share
Government Share
(Gov Take)
37%
33%
Government
67%
$1 Billion
$330 Million - 33%
$670 Million - 67%
WHY WOULD IT HAPPEN?
High Oil Prices
or Low Cost
situation
63%
$1.5 Billion
$555 Million - 37%
$945 Million - 63%
Source: Adapted from Daniel Johnston
The Need For a Progressive Fiscal Regime
Prices, Internal Rate of
Return, Rent..
From B. Land, Taxing the Minerals Industry in Turbulent Times, 2009
(citing PWC report, “Mine: As Good as it Gets?” 2008)
HOW TO FIX THIS SITUATION ?
Easy First Step But Not Optimal :
Progressive vs. Flat Royalty Rates
Progressive Royalty Rate
Price
Rate
Total Royalty Take
$100
7%
$200
8.5%
$17
$300
9%
$27
$7
Flat Royalty Rate
Price
Rate
Total Royalty Take
$100
7%
$7
$200
7%
$14
$300
7%
$21
Reminder: Costs Go Down Naturally
“RENT”
Source: Revenue Watch Institute
What Would Be Such a Progressive Tax?
Resource Rent
Tax Rate
50%
Gradual
increase
If suddenly
the net cash flow is negative
again, the RRT stops kicking in
20%
0%
25%
Threshold
45%
Project Internal
Rate of Return
Resource Rent Tax: Highly tied to profitability and to accumulated cash flow
Can the fiscal regime carry one more input tax and still remain
viable for the investor?
Withholding
Tax
Resource
Rent Tax
Royalty
Tax
Income
Tax
Timing of Different Fiscal Tools
Source: Revenue Watch Institute
Timing matters for developing countries
Optimal Progressive Taxation
Qualities of a progressive fiscal regime?
•
Captures the rent
•
Does not distort investment decisions
•
Self-adjusts to richness of the deposit, price,
cost and risk = capable of accommodating
wide ranges of profitability
•
Avoids the need to change tax regime
(fiscal reforms) according to market and
geological conditions
BUT! Almost NO African countries have progressive taxation!
Less Optimal Progressive Taxation
Other less progressive ainstruments
•
Windfall profit tax (often pricebased)
•
Variable income tax
•
Other sliding-scale instruments
Less progressive but maybe more adapted to the tax
administration capacity
Responsiveness of Proxies to Profitability
Source: IMF
1- Why does extractive industry require a special taxation regime?
2- What is this special taxation system?
3- Why do we need progressive fiscal regime?
4- Why can we speak about a mirage regarding locally held equity ?
5- Capital Gains Tax: What is challenging about it ?
6- Do low income countries need tax incentives to attract investment?
7 - What is the importance of fiscal modeling for host countries?
8- What are the main challenges of fiscal regime design ?
Mirage Of Equity Participation
Paid-up
equity
Carried
interest
So-called
“free” equity
EQUITY
PARTICIPATION
FORMS
Tax
swapped
for equity
Equity in
exchange
for a
non-cash
contribution
Paid-up
equity
for local
ownership
WHY CAN WE SPEAK ABOUT A MIRAGE?
The Mirage – WHY?
Motivation for state
equity
• Economic: share in any upside of a project,
• Non-economic : nationalistic sentiment (DRC),
transfer of technology and know-how (South
Africa), direct control over project development
(Guinea)
Problems
• Can be costly option. (ex: Nigeria)
• Possibly, dividends never paid (widely experienced )
• Possible conflict of interest ( government’s role as
regulator vs equity shareholder. ) (ex: Mozambique)
THE IRONY
• Economic impact of an equity share can in
principle be replicated by tax instruments.
The government is often better off by focusing on taxing and
regulating a project rather than being directly involved as an equity
participant.
State Equity Problems Can be Exacerbated
in the Presence of a SOE
Problems of NOC in general:
- Are assigned contradictory
objectives:
- Providing employment
(China, Russia)
- Providing fuel subsidies
(Saudi Arabia, Venezuela)
- Providing infrastructure
(Nigeria – Angola :
pipelines)
- Foreign policy objectives
(China)
- Answer government’s cash
demand (Mexico)
- And…. Be the National Oil
Company!
1- Why does extractive industry require a special taxation regime?
2- What is this special taxation system?
3- Why do we need progressive fiscal regime?
4- Why can we speak about a mirage regarding locally held equity ?
5- Capital Gains Tax: What is challenging about it ?
6- Do low income countries need tax incentives to attract investment?
7- What is the importance of fiscal modeling for host countries?
8- What are the main challenges of fiscal regime design ?
Capital Gains Taxes and Indirect Transfer
 There is no direct transfer or “assignment” of the rights
in the project. A new agreement (e.g., mining license) is
not signed.
 There is a change in control (“indirect transfer”) ,
happening offshore of the company holding the right/
mining license
 Change in control = sale of shares of either the company
holding the license, or of one of the companies in the
chain of ownership of that company (e.g., the holding
company/ultimate parent company) (sales happening
somewhere in the beneficial ownership)
A Famous Case from Mozambique
AUSTRALIA – STOCK
EXCHANGE
Rio Tinto
Riversdale Mining Limited
MAURITIUS
Riversdale Energy
MOZAMBIQUE
Riversdale Mozambique
Limitada
Rights to the Coal project
Owns the company
Bought
Owns the right
The Regulatory Solution to CGT
 Indirect transfers should also be covered by CGT regs
 All license holders should disclose “beneficial ownership”
 Prior notice of such transactions + with all relevant documents
should be given to the Government
 Sometimes restriction of scope of application (% of mineral assets
ownership or % of shares transferred)
 Enforcement: tax withheld from the purchase price. “Lien” on the
concession agreement and/or other assets of the local company to
cover defaulted tax obligations. Shares of the local company would
be considered to be held in trust for the government.
 Ability to tax depends on DTA – that might only authorize taxation
on residents or taxation on direct transfer
 Challenge: not easy to determine to what extent the value of the non-
resident shares is reflected by an increase in value the host country’s
assets when the non-residents owns several assets!
1- Why does extractive industry require a special taxation regime?
2- What is this special taxation system?
3- Why do we need progressive fiscal regime?
4- Why can we speak about a mirage regarding locally held equity ?
5- Capital Gains Tax: What is challenging about it ?
6- Do low income countries need tax incentives to attract
investment?
7- What is the importance of fiscal modeling for host countries?
8- What are the main challenges of fiscal regime design ?
Different Investment Incentives
Corporate income tax incentives
• Tax holidays or reduced tax rates
• Tax credits
• Investment allowances
• Accelerated depreciation -> tax base – transfer tax burden but doesn’t wave it
• Reinvestment or expansion allowances
Other tax incentives
• Exemption from or reduction of withholding taxes
• Exemption from import tariffs
• Exemption from export duties
• Exemption from sales, wage income or property taxes
• Reduction of social security contributions
Financial and regulatory incentives
• Subsidized financing
• Grants or loan guarantees
• Provision of infrastructure, training
• Preferential access to government contracts
• Protection from import competition
• Subsidized delivery of goods and services
• Derogation from regulatory rules and standards
Developmental Impact of Tax Incentives
TANZANIA
ZAMBIA
• 1992 international
copper prices 2280$/ton
production 400 000 tons:
In coffer: 200 m$
• 2004 copper price
2868$/ton production
400 000 tons:
Text
In coffer : 8m$
•
•
No companies had paid
income tax until 2011
besides Anglogold
Text Ashanti, 10
years after starting production
Barrick Gold 97 million$ between
2004 and 2007 but 0 income tax
Tax Incentives and Loopholes
In addition to progressive decrease in tax rates AND tax base
 Lack of ring-fencing
 Thin capitalization
 Transfer Pricing
70’s-80’s
Washington consensus
REVENUES
COLLAPSED!
2000’s
Do Countries Need Tax Incentives to
Attract Investment?
Mc Kinsey, 2009: “popular incentives, such
as tax holidays (..) serve only to detract
value from those investments that
would likely be made in any case”
IMF, 2009 : “ tax incentives in sub-Saharan
Africa are now used more widely than in
the 80’s with more than two thirds of the
countries in the region providing tax
holidays to attract investment. Such
incentives not only shrink the tax base
but also complicate tax administration
and are a major source of revenue loss
and leakage from the tax economy
DOES THIS ISSUE ONLY AFFECT AFRICA?
IF no Ring Fencing, Government loses!
Project 1
Project 2
- Gross Revenue $750
- Gross Revenue $ 5000
- Total Costs
- Total Costs
$4000
- Net Revenues $3500
- Net Revenues
- Tax (@30%)
- Tax (@ 30%)
$1050
$ 7000
-$
2000
$ 0
Project 1+2 (NO Ring-fencing)
–
Gross Revenues: $12500
– Total Costs: $11000
– Net Revenues: $1500
– Tax (@ 30%) = $450
If the law is silent, you just don’t apply ring fencing of profits
and losses!
Transfer Pricing Practice and How To Limit It?
TRANSFER PRICING PRACTICE
• Definition: prices charged for cross-border
transactions between related parties
• WHAT DO YOU NEED TO SUCCEED ( as a
company) ?
• The creation of an affiliate entity
• To whom you sell exports at below
market price (=‘transfer price’)
• To whom you charge imports/ leasing
at above market price (=‘transfer
price’)
• From whom you borrow at above
market interest rates to highly leverage
projects
HOW TO FIX IT ?
• Regulatory Solution!
Law/ Contract:
1) require arms-length basis transactions
between related parties
( article 9 of UN and OECD Models for DTA)
Difficulty : for some specialized goods and
services , difficult to determine what exactly
is a fair market price.
• Requires closer monitoring
• More reporting
• Requests for comparable transactions
• Cooperation with tax authorities of
home countries
2) impose a cap on the
allowable debt-leverage of a project
$10 bn/ year left Africa between 2002 and 2006 as a result of transfer pricing
Transfer
Pricing Practice
– Example
Transfer
Pricing
(2)
Parent
(UK)
Example: 
Sub1
(British V.I.)
Sub2
(Angola)
Sub3
(UK)
Purchase of Inputs: $100
Sale of Minerals:
$120
Fair Market Value: $150
Fair Market Value: $50
Taxable Profit: $20
Taxable Profit (fair market
value): $100
Source: Revenue Watch Institute
The UN Model Tax Convention Article 9(1)
“Where:
(a) an enterprise of a Contracting State participates directly
or indirectly in the management, control or capital of an enterprise
of the other Contracting State, or
(b) the same persons participate directly or indirectly in the
management, control or capital of an enterprise of a Contracting
State and an enterprise of the other Contracting State,
and in either case conditions are made or imposed between
the two enterprises in their commercial or fi nancial relations
which diff er from those which would be made between independent
enterprises, then any profi ts which would, but for those conditions, have accrued to
one of the enterprises, but, by reason of these conditions, have not so accrued, may be
included in the profits of that enterprise and taxed accordingly”.
A concrete example
Assume a corporation P (parent) manufactures automobile seats in
Country A, sells the finished seats to its subsidiary S in Country B
which then sells those finished seats in Country B to unrelated parties
(say, the public at large). In such a case S’s taxable profits are determined
by the sale price of the seats to the unrelated parties minus
the price at which the seats were obtained from its parent corporation
(cost of goods sold in the accounts of S, in this case the transfer price)
and its expenses other than the cost of goods sold.
If Country A where the seats are manufactured has a tax rate much
lower than the tax rate in Country B where the seats are sold to the
public at large, i.e. to unrelated parties, then perhaps corporation P
would have an incentive to book as much profi t as possible in Country
A and to this end show a very high sales value (or transfer price) of
the seats to its subsidiary S in Country B. If the tax rate was higher
in Country A than in Country B then the corporation would have an
incentive to show a very low sale value (or transfer price) of the seats to
its subsidiary S in Country B and concentrate almost the entire profit
in the hands of Country B. Source: UN Manual
Applying the Arm’s Length principle (ALP) in
practice
•
Several acceptable transfer pricing methods exist, providing a conceptual
framework for the determination of the arm’s length price.
•
All these transfer pricing methods rely directly or indirectly on the comparable
profit, price or margin information of similar transactions.
•
5 major transfer pricing methods:
•

Comparable Uncontrolled Price

Resale Price Method

Cost Plus

Profit Comparison Method

Profit Split
Advance Pricing Agreement (APAs): pricing methodologies agreed in advance in
relation to certain types of transactions, often called the “covered transactions”.
Provide greater certainty for the taxpayer on the taxation of certain cross-border
transactions and are considered by the taxpayers as the safest way to avoid double
taxation
Applying ALP is COMPLEX
Fight against Thin Capitalization:
International Practice

US:
1.5:1 debt-to-asset ratio

Australia:
3:1 debt-to-asset ratio

Canada:
2:1 debt-to-asset ratio

Chile:
3:1 debt-to-asset ratio

Liberia:
interest + 50% taxable income before interest (or as negotiated)

Peru:
3:1 debt-to-asset ratio

Saudi Arabia:
lower of actual interest or interest + 50% taxable income before interest

Sierra Leone:
3:1 debt-to-paid up share capital

South Africa:
3:1 debt-to-asset ratio

Tanzania:
lower of actual interest or 70% of taxable income before interest

Zambia:
3:1 debt-to-asset ratio

Malawi:
4:1 debt-to-asset ratio

Mongolia
3:1 debt-to-asset ratio (only applies to related-party debt)

No Thin Capitalization Rule in
Brazil - China - India - Indonesia - Papua New Guinea – many African countries!
1- Why does extractive industry require a special taxation regime?
2- What is this special taxation system?
3- Why do we need progressive fiscal regime?
4- Why can we speak about a mirage regarding locally held equity ?
5- Capital Gains Tax: What is challenging about it ?
6- Do low income countries need tax incentives to attract investment?
7- What is the importance of fiscal modeling for host countries?
8- What are the main challenges of fiscal regime design ?
As a Starting Point : Fallacy of Discussing
Individual Fiscal Tools in Isolation
Knowing that a royalty is
4%, 5% or 10% will not
give you a sense of
whether the country is
getting a good deal unless
you also know how much
the country earns from
other fiscal tools (profit
taxes, bonuses etc )!
 FISCAL MODELING TO
KNOW THE OVERALL
FISCAL BALANCE!
AND UNDER
DIFFERENT
SCENARIOS!
Fiscal modeling will tell you that Different Combinations
of Fiscal Tools Can Yield the Same Outcome for the
Government
Example 1
Example 2
Corporate Income Tax as
primary tool to extract
revenue
Royalty as primary tool to
extract revenue
 Royalty = $10 million
 Royalty = $45 million
 Profit tax = $40 million
 Profit tax = $5 million
 Total revenue= $50million
 Total revenue = $50 million
Financial Modeling: A Tool For Fiscal And
Public Investment Policy
What long term public investment policy can be
funded and planned?
What is the fairness of the current and potential deals?
WHY Forecasting
the revenue flows
to the government
under different
scenarios ?
What is the equitability of the fiscal regime for investors and
government?
What is the trade-off between “quick money” through signature
bonuses and a higher share of profits ?
What is the efficiency of tax incentives?
If we change the tax regime, what is the impact for the parties?
How does this fiscal regime compare with others?
Fiscal Regimes Are Assessed Against 2 Main Indicators Tested By
The Model
Effective Tax Rate (ETR)
Internal Rate of Return (IRR)
Definition:
Total government taxes
ETR= Cumulative Pre-tax profit
Definition : Makes the positive cash
flows (project revenues) equal to
negative cash flows (initial investments)
- Must be above the cost of capital
Comparing the fiscal regimes based on
this ETR in a selection of countries that
compete for mining investment (“peer
countries”) helps assess the fairness FOR
BOTH PARTIES of the fiscal regime
- The higher the better!
- Can be used to rank several prospective
projects a firm is considering.
- Can be increased by leverage hence the
interest of thin capitalization
Assess what is called the
Government Take in the
project
Assess the profitability of the
project
International Benchmarking Comparing Government Take
AND Profitability Is Needed To Assess The Fairness Of a Deal
Copper Mines
Govt Take=
Effective tax
rate (ETR)*
Percentage
Burkina Faso
Uzbekistan
Ivory Coast
Papua New Guinea
Ghana
Greenland
Mexico
Indonesia
Tanzania
Kazakhstan
Philippines
South Africa
Bolivia
Peru
China
Argentina
Zimbabwe
Poland
Chile
Average
IRR
Percentage
84
63
62
58
54
50
50
49
48
46
45
45
43
43
42
40
40
37
37
3.3
9.3
8.9
10.8
11.9
13
11.3
12.2
12.4
12.9
13.5
13.5
11.4
12.3
12.7
13.9
13.5
12.2
15
49.2
Source: J. Otto et al, Global Mining Taxation
Comparative Study, Colorado School of
Mines
Important Note On Government Take :
Mining Is Not Oil!
Government
Take Mining:
25-60%
Government Take
Oil: 60-80%
WHY?
In mining, a lot more fiscal incentives, no cartel like OPEC to keep
prices up, no progressive fiscal regime, less rent to make
1- Why does extractive industry require a special taxation regime?
2- What is this special taxation system?
3- Why do we need progressive fiscal regime?
4- Why can we speak about a mirage regarding locally held equity ?
5- Capital Gains Tax: What is challenging about it ?
6- Do low income countries need tax incentives to attract investment?
7 - What is the importance of fiscal modeling for host countries?
8- What are the main challenges of fiscal regime design ?
What Are the Common Goals to Take Into
Account in a Fiscal Regime Design ?
 Government Take/Overall fiscal balance adapted to level of
attractiveness of the mineral/ hydrocarbon deposits
 Government Take/Overall fiscal balance competitive with the
peer group countries
 Government Take not collapsing over time
 Government Take/Overall fiscal balance adapted to capacity of
the tax administration
What Are the More Country-Specific
Objectives?
Source: IMF
Tax Administration Capacity and Policy
Design
 Possible trade-off between progressivity and ease of
administration
The simplest fiscal tools to administer (bonuses and royalties) are also the least
progressive …whereas the most complicated (resource rent taxes) are the
most progressive.
“Most complicated” means high risk of leakages in low capacity governments
 Possible trade-off between efficiency/credibility and ease of
administration
Ex: price-based taxes may eventually become untenable and require adjustment
if costs rise disproportionately and thus decrease profit margins
Policy response ?
DON’T GIVE UP ON PROGRESSIVE TAX
REGIMES BUT INVEST IN CAPACITY
BUILDING !!
-> MINIMIZE TRANSFER PRICING
-> STANDARDIZE CONTRACTS
-> FOCUS ON THE MAIN REVENUE STREAMS
-> ELIMINATE MINOR TAXES