Developing Nations Get New Transfer Pricing Guidance for Lithium

The Organization for Economic Cooperation and Development on Monday published transfer pricing guidance to help developing countries raise revenue from lithium operations in their jurisdictions.

The lithium transfer pricing framework laid out by the OECD together with the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) uses the comparable uncontrolled price method, or CUP, to determine the price of lithium between related companies.

The CUP method of transfer pricing requires a company to compare its controlled transaction of lithium—between two entities within their corporate group—and the same kind of “uncontrolled” transaction between two unrelated companies.

The ...