Australian Taxation Office probes Greenbushes lithium mine transfer pricing scheme amid another huge profit

Revelations of an ongoing audit by the taxman overshadowed a net profit of more than $600 million in 2025 from Australia’s largest and highest-margin lithium mine. The Greenbushes mine in WA’s South West once again spat out a sizeable paper profit for its three owners — the US-based Albemarle (49 per cent), Chinese firm Tianqi Lithium (26 per cent) and ASX-listed IGO (25 per cent). Revenue from Greenbushes dropped from $1.97 billion in 2024 to $1.68b last year, while dividends dove from $877.3m to $223.4m as cash was hoarded to fund construction of the mining operation’s third chemical grade plant. Lower spodumene concentrate prices were partially offset by a favourable $238m foreign exchange swing owing to the Australian dollar falling against the greenback. Greenbushes generated $623.8m of net profit for 2025, which was a $86.3m decline from the prior year’s result but takes the cumulative bottom line since 2020 to a whopping $10.7b. The Australian Taxation Office is now delving into the bumper profits reaped by the mine’s holding company in recent years. “Windfield Holdings has been advised that the ATO will be conducting an audit over the 2020 to 2024 income years in relation to historical transfer pricing matters,” the private company stated in its financial report lodged on Monday. No further detail about the audit was provided. Transfer pricing relates to transactions across international borders between related parties. It is a tax evasion technique used by multinational companies to shift profits out of a country. The ATO appears to be increasingly cracking down on the practice within Australia’s mining industry. Greenbushes spodumene concentrate is sold almost exclusively to Tianqi and Albemarle under long-term offtake agreements. Most of the product bought by both ends up at lithium refineries they separately own in China. The latest ATO audit marks an escalation of scrutiny into the joint venture arrangements surrounding Greenbushes and the downstream processing infrastructure linked to the mine. Tianqi and IGO own their portions in Greenbushes via the Tianqi Lithium Energy Australia joint venture and in November last year it was revealed an ATO probe into TLEA was jeopardising the JV’s ability to reach into a $17.6b pot of Australian tax credits. The ATO’s under-the-radar pursuit of Tianqi stems from the Chinese firm’s 2020 agreement with South Perth-based IGO to create TLEA. TLEA owns the perennially loss-making Kwinana lithium hydroxide refinery outright, in addition to its Greenbushes stake. “The ATO continues to focus on arrangements whereby a restructure by (a) multiple entry consolidated group enables a tax free exit from Australian investments,” a Tianqi subsidiary stated last year. “Tianqi is currently engaging with the ATO in respect of the IGO transaction to obtain certainty of the tax outcomes. The outcome and timing are uncertain at this stage. “If the ATO sought to apply Part IVA Income Tax Assessment Act 1936 to the IGO transaction and the internal restructure, based on what is considered the counterfactual most likely to be put forward by the ATO, this could give rise to a primary tax liability and penalty, which may have a significant impact on the financial results.” TLEA’s Kwinana refinery stands to be eligible for a big chunk of the $17.6b Federal Government’s production tax credit package for downstream processors of critical minerals. Those tax credits kick in from July 1 next year.