The proposed MRRT is a potentially complex tax requiring the application of concepts from income tax and goods and services tax (GST) legislation, together with the use of the Organisation for Economic Co-operation and Development (OECD) transfer pricing guidelines, mining law, accounting concepts and market valuation principles.
The ED is not exhaustive, and is intended to provide stakeholders with an early overview of the legislation and allows those who wish to make further comment to do so before the legislation is finalised later this year. The Government has indicated it intends to release a second and final ED on the proposed MRRT for public consultation later in the year.
Our brief provides a summary of the key concepts within the ED and EM and and includes KPMG’s observations on matters that will be relevant in finalising the MRRT legislation.