This is an independent report by Eunomix which provides an analysis of the UNCTAD study which pointed towards a systematic practice of mis- and under invoicing among mining companies in selected countries, alleging that the mining industry has been engaging in this practice with the direct objective of avoiding taxes or, at the very least, reducing tax burdens in producing countries. Specifically, the report states that mining and oil companies have misappropriated as much as 67% of the export revenues of the countries studied, most of which would occur out of South Africa. In response to criticism of its preliminary analysis, UNCTAD released an updated version in December 2016, which looked at new data sources in South Africa. The report’s methodology did not change and results for South Africa changed marginally. In October 2016 the Chamber of Mines of South Africa engaged Eunomix to independently review the UNCTAD report, with a focus on South Africa’s exports. We released an initial report in December 2016 focused on gold, and followed with a complementary note in February 2017. This report provides a comprehensive counterfactual on all South African exports analysed by UNCTAD, based on its December 2016 release.