A. Why This Workshop Matters Now

Coal mining companies are operating in a regulatory environment where tax exposure is increasingly shaped by how contracts are structured, projects are designed and costs are recognized across the mine life cycle—long before any return is filed.

Mining services, hauling and equipment agreements that are commercially rational can, under audit, generate withholding tax, VAT or permanent establishment exposure if risk allocation and scope of work are not aligned with the relevant tax characterization. Deferred stripping, reclamation provisions and PPM expenditures may be booked consistently in financial statements yet still face different interpretations during tax examinations or VAT refund processes. Early-stage exploration, development activity and pilot sales now sit within a tighter interaction between mining regulation and the Harmonized Tax Law, requiring closer alignment between operational choices and their fiscal treatment.

Related-party coal sales and logistics arrangements are subject to heightened scrutiny under benchmark pricing frameworks and transfer pricing documentation standards. At the same time, organizational separation between operations, commercial, legal, finance and tax often mean fiscal considerations enter only after contractual and structural decisions have been finalized.

The broader regulatory landscape reinforces this shift. The transition from CCoW/PKP2B regimes to IUP under prevailing-law compliance, the implementation of Government Regulation No. 18 of 2025 on mining tax treatment, tighter PNBP and DMO supervision, and the expansion of data-driven audit techniques have all narrowed interpretative flexibility. Production data, customs records, financial reporting and tax filings are now routinely cross-checked and assessed as a single narrative.

Fiscal exposure therefore arises less from isolated filing errors, and more from the underlying commercial architecture. This two-day program is designed to address that reality.

Day One examines governance and commercial structuring risk; Day Two focuses on operational execution and audit readiness. Together, they provide a practical framework to identify, manage and mitigate tax exposure across the coal value chain before it escalates into dispute.

B. Benefits of Attending

By the end of the two days, participants are expected to:

• Understand how mining licenses, contracts and cost structures create tax exposure long before filing, and how to build a cross-functional “tax gate” at that stage.
• Reduce recurring disputes in high-risk areas such as exploration and development costs, deferred stripping, reclamation, PPM and VAT refunds.
• Strengthen defensibility of related-party coal sales and logistics arrangements under benchmark-based pricing and transfer pricing scrutiny.
• Map operational tax risk in daily mining transactions and embed simple, practical controls in documentation, classification and timing.
• Build a 90-day internal roadmap to improve contract review, documentation discipline and audit readiness.

C. Who Should Attend

• Chief Financial Officers / Finance Directors
• Heads of Tax, Tax Managers, Tax Planning Managers
• General Counsel / Legal Managers and Commercial Managers
• Senior Operations Leaders (production, planning, contracting)
• Internal audit, finance and tax teams in coal mining groups

Benefits:

• E-certificate of completion.
• Digital training materials (PDF) for internal use.
• Limited post-workshop consultation with the facilitator. Active participants may be invited to a complimentary follow-up consultation within 14 days.