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🪙 Zambia’s $13M Benchmark: Mopani Copper Set the New Standard

August 21, 2025

Extended Background

Resource extraction MNEs, including Mopani, were traditionally able to shift profits abroad using related-party trading companies. Zambia’s challenge marked a turning point, with support from the OECD to strengthen local capacity and implement real benchmarking in mining.

Detailed Arguments

Taxpayer

  • Pointed to global copper pricing volatility, arguing that “in-market” trading and logistics justified discount pricing to affiliates.

  • Presented internal documents justifying the structure.

Revenue

  • Provided independent global pricing indices and shipping evidence to argue for higher value retention in Zambia.

Outcome

  • Zambian authorities won a landmark $13M adjustment, signaling a new era of evidence-based enforcement.

Procedural Journey

  • Case developed via major audits and international peer support, resolved domestically without lengthy litigation.

Implications Beyond the Case

  • Other African extractives must rigorously document pricing decisions and expect much higher scrutiny on transfer values.

Original Case Link:

OECD Zambia case PDF
Editorial Note:

Official judgments are always best linked to directly from court or sovereign government sites (PDFs or HTML), or through leading law firm/academic sources with appropriate commentary and official citations. Cases without direct links either are not fully published due to confidentiality or are referred to trusted legal commentaries.

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