• Two lithium mines, Goulamina and Bougouni, raise transfer pricing concerns

• Sales tied to foreign parent companies risk lowering taxable revenues

• Authorities tighten scrutiny to ensure Mali captures fair share of lithium

With the launch of the Goulamina lithium mine in 2024 and Bougouni in 2025, Mali is increasingly exposed to transfer pricing practices in its mining sector. Transfer pricing refers to financial, commercial, or technical transactions between a local subsidiary and its foreign parent company, which can create risks for tax authorities in resource-rich countries.

Such practices may involve selling minerals to a group affiliate abroad, invoicing technical services by the parent to the local subsidiary, or using patents and trademarks within the same group. Because these deals take place inside the same corporate structure rather than on an open market, determining fair value is complex and subject to interpretation.

Lithium illustrates this challenge. Unlike gold or consumer goods with clear benchmarks, lithium pricing is opaque. It is harder to track trends and know what the ‘right price’ should be, according to said Adam Megginson, analyst at Benchmark Mineral Intelligence, in comments to Ecofin Agency.

Both of Mali’s first lithium projects reflect this issue. At Goulamina, majority shareholder Ganfeng Lithium (65%) expects to produce 506,000 tons of lithium concentrate in Phase I, potentially rising to 1 million tons in Phase II. Ganfeng, which controls the entire lithium value chain, has already indicated the mine will supply it with “high-quality, low-cost” concentrate for its downstream carbonate and hydroxide plants.

At Bougouni, UK-based Kodal Minerals signed a deal in June 2025 with its Chinese partner Hainan Mining to sell all spodumene concentrate output to the latter for four years.

First spodumene production from Bougouni

“Malian authorities must therefore deal with transfer pricing, where the Chinese subsidiary resells material to itself. In these cases, the declared price can be lower than market price. And it is quite difficult to prevent this,” Megginson added. The sales price of lithium—and therefore the value of these contracts—will partly determine Mali’s mining revenues, since certain royalties are indexed to sales values.

Mali’s fiscal tools for transfer pricing

Mali already has tax rules to address such practices. The General Tax Code requires transactions between related companies to follow arm’s-length conditions. Firms with significant business involving foreign affiliates must also produce detailed documentation on intra-group transactions. Article 57-E allows companies to request an advance pricing agreement (APA) from the tax administration to set transfer pricing methods in advance.

“An APA determines, before transactions between associated enterprises, an appropriate set of criteria such as calculation methods, comparables, or adjustments, for the transfer prices applied during a given period,” explained tax lawyer Demba Traoré in a note published by CERACLE.

Meanwhile, Kodal Minerals’ CEO said in May 2025 that exports from Bougouni are currently suspended, as the government insists lithium be sold at market prices.

While authorities have not commented, the move signals tighter vigilance over a fiscal risk that is new for Mali. For a country where gold has been the top mining product, the challenge is not only to launch a new lithium industry but also to ensure that the value of this “white gold” is captured domestically rather than lost abroad through transfer pricing.