What changed?
No single regional framework consistently addresses mineral-sale underpricing, related-party financing and offshore indirect transfers across Central Asian mineral projects.
The OECD paper maps these three risks and recommends closing legislative gaps. It is policy analysis and does not itself amend domestic tax law or the OECD Transfer Pricing Guidelines.
Practical consequence: Mining groups and investors should document mineral pricing, related-party debt, holding structures and exit-tax exposure, while monitoring each jurisdiction for actual legislative changes.
What happened?
On 29 October 2026, the OECD published Critical minerals in Central Asia: A regional overview, OECD Global Relations Policy Papers No. 2026/04. The 49-page paper examines the region’s mineral potential, environmental and governance issues, investment conditions and fiscal risks.
Its tax chapter identifies three main base erosion and profit shifting risks: underpricing mineral sales, abusive related-party financing and offshore indirect transfers of mining licences. The publication is an OECD policy paper and recommendation set, not enacted law or an amendment to the OECD Transfer Pricing Guidelines.
Key details
Mineral sales may be priced below arm’s length when output is sold to related or coordinated entities in low- or no-tax jurisdictions and then resold at market value. The risk is greater for minerals without transparent benchmark prices. The OECD notes that this can reduce corporate income tax, ad valorem royalties, profit-based rent taxes and, through lower reported profits, dividend withholding tax.
The financing risk concerns high interest rates, inflated debt levels and equity-like instruments presented as debt. The report says legal and administrative capacity to challenge such arrangements remains uneven across the region.