Tax treaty issues

The extractive industries play an important role in the process of sourcing natural resources, which are critical for the development of many economies. Both developing and developed countries are actors in the process of natural resource extraction, both as host countries to the extractive activities and also as countries where the extractive industries companies have their head offices, raise capital and make strategic decisions. Extractive activities often include a cross-border element, due to global business models and integrated value chains. They are undertaken by investors, licence holders, service providers and suppliers who are often not resident in the source country. In this context, a number of international tax issues arise.