In Sierra Leone, strengthening the taxation of multinational enterprises in the extractive sector is gaining momentum through focused support on transfer pricing.
Working alongside officials from the National Revenue Authority (NRA), ATAF provided hands-on support grounded in the realities of taxing mining, oil and gas operations.
The work centred on practical audit scenarios, looking at how value is created across extractive value chains and how that value should be reflected for tax purposes. It also unpacked some of the more complex areas administrations encounter in practice, including mineral pricing across different stages of production, the application of transfer pricing methods, and the use of structures such as marketing hubs and offshore indirect transfers.
The approach was deliberately practical. Sessions were built around real challenges faced by the NRA, creating space to test approaches, ask questions, and work through issues in detail.
The support also looked at aspects of the legal framework governing the taxation of multinational enterprises in the sector, with a focus on how existing rules are applied in increasingly complex cross-border arrangements.
