The discovery and start-up of lithium mines in Mali is a turning point for the country’s production structure. Traditionally dependent on gold, Mali now faces the challenge of managing a strategic resource for which global demand is growing exponentially, given its role in the energy transition and production of batteries.
The launch of projects such as Goulamina (2024) and Bougouni (2025) introduces not only opportunities for economic diversification but also a set of complex tax risks, mainly related to pricing in intra-group transactions. Unlike gold, lithium lacks a transparent international market with public reference quotations, which makes it easier to manipulate transfer prices.
Market Opacity and Tax Erosion Risks
One of the main issues identified is the difficulty of determining the “fair price” in related-party transactions. In Goulamina, for example, Ganfeng Lithium, which owns 65% of the project, manufactures and exports concentrates internally within its multinational group. In Bougouni, production is entirely destined for Hainan Mining, also linked to the consortium.
In this context, there is a risk that the prices declared for intra-group sales are below market value, artificially reducing the taxable base on which royalties and taxes are calculated in Mali. Therefore, the tax administration must take preventive action to avoid tax losses in a sector with high tax collection potential.
Current Regulatory Framework and Control Mechanisms
Mali’s General Tax Code stipulates that related-party transactions must be carried out under the Arm’s Length Principle. Additionally, companies with significant revenues must file documentation supporting the appraisal method employed in their cross-border transactions.
A key tool in this framework is the possibility of resorting to advanced transfer pricing agreements, which allow the administration and companies to agree in advance on the applicable parameters. This instrument, theoretically valuable, requires strong technical capabilities on the part of the tax authorities to evaluate methodologies, margins, and comparables in a non-transparent market as that of lithium.
Practical Barriers: Delays and Precautionary Measures
The challenges are not only regulatory. In 2025, the Bougouni mine began to produce, but exports were delayed because the state had not yet approved the pricing mechanism. The buyer, Hainan Mining, is ready to receive the ore, but export authorization remains on hold.
This scenario reflects the tension between the need to attract foreign investment and the obligation to safeguard the country’s tax interests. The government, aware of the risks of undervaluation, has opted for a cautious approach, even if it entails delaying the first export revenues.
Institutional Strengthening and Mining Reforms
The lithium issue is part of a broader context of tax and mining reforms. In 2023, Mali approved a new Mining Code that increases government ownership in projects, adjusts tax benefits, and strengthens control powers. These measures intend to grow tax collection and mitigate aggressive tax planning practices observed in sectors such as mining and telecommunications.
In addition, recent audits by the tax administration have intensified the supervision of intra-group transactions. The message is clear: Mali is not willing to repeat the experiences of tax erosion, such as those observed in other African countries rich in natural resources.
International Recommendations and Future Outlook
The International Monetary Fund (IMF) had already warned in 2018 that, in developing countries with extractive industries, Transfer Pricing poses a considerable risk to the stability of public finances. The organization recommended simplifying appraisal methodologies, strengthening transparency, and limiting excessive tax incentives that favor tax base erosion.
In Mali’s case, these recommendations become particularly urgent: The lithium mining provides a historic opportunity to consolidate tax revenues, but at the same time could become a source of tax disputes if plain and efficient control mechanisms are not designed.
Conclusion
Lithium represents a promise of economic diversification and a potential boost to Mali’s tax revenues. Conversely, the complexity of its market and the presence of large multinationals pose a challenge regarding Transfer Pricing.
The country will need to balance between attracting foreign investment and protecting its tax base by strengthening technical capacities, leveraging prior pricing agreements, and adopting international best practices. Only through a rigorous and sustained tax strategy can “white gold” become an engine of sustainable development rather than another example of lost tax sovereignty.
Sources:
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https://www.ecofinagency.com/news-industry/0309-48395-mali-faces-tax-challenge-of-transfer-pricing-in-new-lithium-sector
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https://www.ecofinagency.com/public-management/0908-44783-mali-adopts-new-mining-code-to-boost-public-revenues
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https://www.africanews.com/2023/08/31/mali-adopts-new-mining-code-to-raise-gold-concessions-ownership/