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International Centre for Tax and Development
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The International Institute for Sustainable Development is a globally recognized think tank with more than 30 years of experience working to solve today's greatest sustainable development challenges. We combine deep expertise across critical policy areas with a collaborative approach to research, advice, and hands-on support that delivers real-world results. Headquartered in Winnipeg, Manitoba, we are a diverse team of over 300 experts working from offices in Canada and Switzerland as well as other locations around the world.
IISD hosts the Secretariat of the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF).
The IGF's Global Mining Tax Initiative (GMTI) helps countries to increase mining revenues for sustainable development. Drawing on broad experience working with IGF member governments, the Secretariat offers this specialized and comprehensive program covering fiscal policy for the entire mining value chain, from exploration and development to mining, processing, mineral sales, and mine closure. The GMTI focuses on all aspects of fiscal policy, including taxes, royalties, and financial modelling, and has developed particular expertise on the fiscal treatment of mineral beneficiation and downstream processing.
Background
In 2025, the Organisation for Economic Co-operation and Development and the IGF jointly published Ring-Fencing Mining Income: A Toolkit for Tax Administrators and Policy-Makers, a comprehensive practice note on when and how governments should limit the consolidation of income and expenditure across mining projects and activities. The toolkit addresses the treatment of integrated operations in several places, notably its discussion of ring-fencing by shared processing facility, ring-fencing of upstream versus downstream activities, and its recommendation that transfer pricing rules extend to internal dealings within a single ring-fenced entity.
The toolkit's treatment of integration is oriented toward the design of the ring-fencing rule itself: where the statutory boundary should sit when a mine feeds a processor, and how to prevent profit-shifting across that boundary once drawn. There is a separate but distinct question to consider, namely how ring-fencing rules interact with the value-addition (beneficiation) tax and non-tax incentives that many of the same governments offer to draw investment into downstream processing. Specifically, this would include such incentives as tax holidays, accelerated depreciation, royalty rate differentials for refined versus unrefined product, and preferential processing licences. Where such incentives sit on one side of a ring-fence and the extraction activity sits on the other, the incentive may fail to achieve its stated purpose (because start-up losses in the incentivized processing segment cannot offset profits in the ring-fenced mining segment), or it may create the very transfer-pricing and rate-arbitrage risks the toolkit is designed to guard against.
The Challenge
Tax policy-makers and administrators currently have authoritative guidance on ring-fencing design (the 2025 toolkit), and there is separate literature on mineral beneficiation incentives (such as from the International Monetary Fund, World Bank, International Council on Mining and Metals tax expenditure work), but there is no practice note that puts the two together: a framework for how a value-addition incentive should be designed, and where the ring-fence should sit, when the two instruments apply to the same integrated project. This gap matters because the interaction is not merely theoretical. It shows up directly in country practice already surveyed by the toolkit and by the IGF's own country work: a differentiated corporate income tax rate for mining versus mineral processing licences, a statutory carve-out permitting pooled treatment of “inseparable or substantially interdependent” integrated beneficiation operations, and processing facilities sited in export processing zones specifically to capture preferential tax treatment.
Our Response
The IGF seeks to develop a practice note on the ring-fencing implications of mining value-addition incentives for integrated mining projects, in continuation of the 2025 Ring-Fencing Mining Income toolkit. The note will take the toolkit's existing design guidance on integrated operations as its starting point and extend it to address the incentive-interaction question: how should a ring-fencing regime be designed, and how should a value-addition incentive be designed, so that the two are coherent rather than potentially working against each other on the same integrated project?
The country case set will be determined jointly with the consultant at inception stage. Candidates must include jurisdictions that illustrate materially different design choices. Such design choices include a statutory integration test permitting pooled treatment of extraction and processing under common control, a differentiated tax rate between mining and processing licences, strict project-level ring-fencing with value addition pursued through the royalty schedule rather than through ring-fencing relief, and vertical integration achieved through trade policy (export restriction) rather than through the ring-fencing rule as such. Ghana and Tanzania are both covered in the toolkit's shared-processing-facility and upstream/downstream discussions and are also considered as candidates in this study because they build directly on documented toolkit examples rather than introducing an unrelated set of countries.
Deliverable – Technical Input for the Ring-Fencing and Value Addition Practice Note
The IGF seeks a consultant, or small consultant team, with expertise in mining fiscal policy and comparative tax law to conduct desk-based research and support the drafting of the practice note. The work is weighted toward legal and literature research rather than field consultation. The consultant will be responsible for the following tasks:
Timelines
Location: Remote
IISD will not apply for residency and work permits for this position on behalf of the applicant.
Candidates must hold appropriate work authorization for locations where they expect to be based.
Application Process
Application deadline: Applications will be reviewed on a rolling basis until filled.
This is a consultant position. Submissions must be in English.
To apply for this consultancy, interested applicants should submit the following:
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