Determining the loss of mining sector tax revenue: Evidence from Mongolia

In recent years, due to significant tax revenue losses, transfer pricing has become an issue of concern for tax authorities, policymakers, and academics. In this study, the authors aim to analyze transfer pricing and its impact on fiscal revenue in the case of Mongolia, a developing country with a mining-dominated economy. In our research, we used the arm's length principle to determine transfer pricing and estimate the loss of corporate income tax due to transferring pricing; moreover, we compared the operating profit margin of Mongolia’s mining companies with the Far East and Central Asia Oceania countries. We found that Mongolia has lost about 44.4 billion MNT in corporate income tax revenue from the mining sector over the past seven years, estimated by adjusting the total operating revenue by an average of 10.5% for coal companies and 16.4% for copper companies. This result shows that mining companies are avoiding taxes by mispricing, which negatively affects the budget revenue in Mongolia. This research will contribute to the implementation of the common principles of transfer pricing and reduce tax evasion in Mongolia and similar countries with a mining-dominated economy.