Consultant - Metal Streaming and Private Royalty Agreements

About

The International Institute for Sustainable Development (IISD) is an award-winning independent think tank working to accelerate solutions for a stable climate, sustainable resource management, and fair economies. Our work inspires better decisions and sparks meaningful action to help people and the planet thrive. We shine a light on what can be achieved when governments, businesses, non-profits, and communities come together. IISD’s staff of more than 300 experts come from across the globe and from many disciplines. With offices in Winnipeg, Geneva, Ottawa, and Toronto, our work affects lives in nearly 100 countries.

The Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF)’s Global Mining Tax Initiative (GMTI) helps countries to increase mining revenues for sustainable development. To that goal, we develop innovative, forward-looking policies; build relationships and coalitions to influence global norms and standards; and adopt a systematic, long-term approach to technical assistance. Ecuador is one of the countries that has been able to benefit from our assistance.

Scope

Mines require significant capital investment throughout their life cycle. Spending begins relatively modestly with exploration and development but rises sharply during mine construction and the development of associated facilities. These investments—often amounting to hundreds of millions of dollars—cover the construction of the mine, ore processing or beneficiation plants (or facilities to extract materials such as gemstones), as well as supporting infrastructure like power generation, worker housing, offices, and transport links (e.g., roads and pipelines).

As financial markets have become more diverse and sophisticated, mining multinational enterprises now finance their projects using a wide range of mechanisms. In addition to “traditional” sources, such as external loans, mining multinational enterprises increasingly rely on “alternative” arrangements. These include metal streaming agreements—where upfront payments secure the right to purchase mine production at discounted prices—and private royalty agreements, under which financiers receive payments based on a share of production value. These financing arrangements are increasingly being used by mining companies in Latin America, including in Ecuador, to secure upfront capital by pledging future mineral production or revenues.

The complexity of these arrangements requires tax administrations to build expertise in both mining and finance. To audit such transactions effectively, tax auditors need a clear understanding of alternative financing structures, particularly metal streaming and private royalty agreements. Strengthening this knowledge will help governments ensure the correct collection of taxes and royalties while also enhancing their capacity to manage increasingly complex contractual arrangements.

Against this background, the GMTI is seeking a consultant to deliver the following deliverables.

Training on Metal Streaming and Private Royalty Agreements

IGF will provide a training session related to metal streaming and private royalty agreements for representatives from the Internal Revenue Service (SRI) from Ecuador. The training should be delivered for at least 6 hours in November 2025. The training should cover at a minimum the following areas:

• History and current uses


• Commercial rationale outlining the benefits they offer to both streaming companies and mining operators


• Parties and structures


• Where these agreements fit in the life of a mine


• Key contractual terms, including (where applicable): price, deliveries, incoterms, remedies for failure to take, remedies for failure to pay, specification (timing, process to change, sampling, off-spec (non-conforming))

The Consultant will be responsible for developing the agenda, preparing training materials, and delivering the program. In close collaboration with the IGF team, the Consultant will ensure that the training is tailored to the specific context and audience. IGF will provide feedback on the agenda and the training materials. The role may also involve reviewing relevant local laws and regulations to inform the program’s design and delivery.

The Consultant should consider that the SRI is interested in developing new tax policies to optimize revenue from these types of transactions while also addressing profit-shifting risks that may arise from financial transactions between related parties.

The training session will be recorded for additional use by Ecuador.

Support the Development of a Practice Note on Metal Streaming and Private Royalty Agreements

In addition to providing technical assistance to Ecuador, the Consultant will support the development of a concept note examining the fiscal implications of metal streaming and royalty agreements in the mining sector. Specifically, the Consultant will develop a chapter related to the “Mining business and the Use of Alternative Financing Sources: Metal Streaming and Private Royalty Arrangements.” This chapter will cover, at a minimum:

• An introductory briefing: The capital-intensive nature of mining and how metal streaming and private royalty agreements fit in the life of the mine


• Key definitions: Overview of what they are, their commercial and economic characteristics, the parties involved, and the different types of structures


• Company financing decisions and access to external capital: Why do companies use these types of external financing, among other factors that affect the use of metal streaming and private royalty arrangements?

A strong chapter on the commercial side of metal streaming and royalty arrangements will allow the Organisation for Economic Co-operation and Development and IGF to analyze how these structures pose complex challenges for governments in terms of tax base erosion.

Expected Deliverables

• Annotated outline of chapter


• Draft research paper, including
  
  
  
  • Executive summary (two pages max)
  
  
  • Revised full-length paper (8,000–10,000 words)
  
  
  • Bibliography and reference list
  
  
  
  

Timeline

Training: By November 30, 2025

Research: By December 31, 2025

Qualifications

• Extensive experience in the mining private sector (e.g., mining companies, law firms), with a strong focus on deal structuring and drafting/negotiating streaming terms.


• Strong writing and analytical skills, with a track record of high-quality research outputs.


• Advanced degree in international mining transactions, international mining law, international corporate law, or a related field is desirable.


• Experience working with or advising international organizations or governments is desirable.
  
  

Location

Remote. IISD will not be applying for residency, and work permits for this position on behalf of the applicant.

Deadline of Application

Applications will be reviewed on a rolling basis until filled.

Application Process

This is a consultant position. Submissions must be in English.

Candidates must hold appropriate work authorization for locations where they expect to be based.

Please include the following:

• A CV


• An expression of interest (one page)


• Writing sample (preferably related to tax, mining, investment, or trade dispute resolution)

Only those candidates we wish to interview will be contacted.

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