Cantonnement des revenus miniers

The document examines 'ring-fencing'—the practice of limiting the consolidation of revenues and deductions for different activities or projects undertaken by the same taxpayer—as a tool for governments to protect the mining tax base. It analyzes the trade-offs between accelerating public revenue and potentially discouraging investment, particularly in marginal deposits. The guide details various design options, such as ring-fencing by mining license area, activity (upstream vs. downstream), or separating mining from non-mining activities. It also provides practical recommendations on allocating indirect and general expenses, managing national transfer pricing risks, and handling permanent losses from unsuccessful exploration to balance revenue needs with investment incentives.

• Ring-fencing accelerates the collection of public revenues by preventing companies from using costs from new or unsuccessful projects to offset profits from existing productive mines, which would otherwise defer tax payments for years or decades.
• The practice is most prevalent in Africa, where 64% of the jurisdictions in the study sample that have mining ring-fencing rules are located.
• A significant risk of ring-fencing is that it may discourage investment in marginal ore deposits or new exploration because investors cannot recover losses across their entire portfolio in the country.
• The most common and manageable form of ring-fencing is by mining license area, as it aligns tax treatment with the specific geographic location defined in the regulatory permit.
• To prevent the erosion of the tax base, governments may explicitly ring-fence upstream activities (exploration, development, production) from downstream activities (processing, refining, transport, marketing), especially when different tax rates apply.
• For profit-based taxes like Resource Rent Tax (RRT) or Additional Profits Tax (APT), ring-fencing is essential to ensure they are triggered when a specific project reaches its internal rate of return (IRR) threshold, rather than being delayed by losses in other projects.
• To balance revenue goals with exploration incentives, some countries (e.g., Kenya, Papua New Guinea, Cook Islands) allow limited recovery of permanent losses from unsuccessful exploration through gradual deduction over several years.
• To mitigate the risk of internal profit shifting within a single legal entity, governments should apply transfer pricing rules to internal transactions between ring-fenced projects.

APA

International Institute for Sustainable Development (2025). Cantonnement des revenus miniers. https://www.iisd.org/system/files/2025-10/ring-fencing-mining-income-toolkit-fr.pdf

Chicago

International Institute for Sustainable Development. Cantonnement des revenus miniers. 2025. https://www.iisd.org/system/files/2025-10/ring-fencing-mining-income-toolkit-fr.pdf.

Wikipedia

{{cite report |author=International Institute for Sustainable Development |title=Cantonnement des revenus miniers |date=2025 |url=https://www.iisd.org/system/files/2025-10/ring-fencing-mining-income-toolkit-fr.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{internationalinstituteforsustainabledevelopment2025cantonnement, author = {{International Institute for Sustainable Development}}, title = {{Cantonnement des revenus miniers}}, institution = {International Institute for Sustainable Development}, year = {2025}, url = {https://www.iisd.org/system/files/2025-10/ring-fencing-mining-income-toolkit-fr.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }