Bills Digest no. 154 2005–06
Petroleum Resource Rent Tax Assessment Bill
This Digest was prepared for debate. It reflects the legislation as
introduced and does not canvass subsequent amendments. This Digest
does not have any official legal status. Other sources should be
consulted to determine the subsequent official status of the
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Petroleum Resource Rent Tax Assessment Bill
Date introduced: 25 May 2006
House: House of
Commencement: Various dates as set out in the table in clause 2.
In most cases, the commencement date is 1 July 2006.
To amend the
Petroleum Resource Rent Tax Assessment Act 1987 (PRRT Act)
allow deductibility of transferable exploration
expenditure when calculating quarterly petroleum resource rent tax
(PRRT) instalment payments
allow deductibility of fringe benefits tax for PRRT purposes
include PRRT in the self-assessment regime
introduce roll-over relief for taxpayers undergoing
internal corporate restructuring
allow deductibility of project closing-down costs when
converting a production licence to an infrastructure licence
extend the lodgement period for annual PRRT returns from
42 days to 60 days, and
introduce a transfer notice requirement for vendors disposing of
an interest in a petroleum project.
The PRRT is a federal tax on 'economic rent'. Rent is a payment
to a factor of production, such as labour, that exceeds the amount
necessary to keep that factor in its current occupation. For
example, if a person receives a salary of $50 000 but would
earn $40 000 in the next best alternative employment, the
person receives rent of $10 000.
The Department of Industry, Tourism and Resources describes the
PRRT as follows:
PRRT is a profit-based tax, which is applied
to a project. Each entity with an interest in a
PRRT liable project will be liable for that PRRT. A project
consists of facilities in the project title area, and any
facilities outside that area necessary for the production and
initial storage of marketable petroleum commodities (MPCs), such as
stabilised crude oil, condensate, natural gas, liquefied petroleum
gas, and ethane. Value added products, such as LNG, are
excluded.(1) The PRRT provides the community the
ultimate owners of Australia's petroleum resources with a share of
the returns from the exploitation of scarce and non-renewable
The PRRT applies to:
all projects seawards of the outer limits of the
territorial sea. The exceptions to this coverage are for those
production licences drawn from the North West Shelf project area
(Exploration Permits WA-1-P and WA-28-P) where Commonwealth excise
and royalty applies (including Australia s only liquefied natural
gas export operation), and certain areas within the Timor
Features of the PRRT include:
∙ it is assessed on a project basis
∙ liability to pay PRRT is on a
∙ PRRT is levied before company tax
∙ PRRT payments are deductible for company
∙ PRRT is assessed at the rate of 40 per
∙ liability for the PRRT is incurred when
all allowable expenditures, including compounding (see next dot
point), have been deducted from assessable receipts (Division 3 of
Part V of the PRRT Act deals with deductible expenditure)
∙ any excess of expenditure over receipts
can be compounded forward (augmented) for deduction against future
receipts from the project
∙ the rates at which undeducted expenditures
are compounded forward depend on the nature of those expenditures
and when they were incurred before the granting of a production
∙ deductions include capital and operating
costs that directly relate to the petroleum project, and are
deductible in the year they are incurred. Deductible expenditures
include exploration, development, operating and closing
∙ expenditures which are not deductible
include financing costs, indirect administration costs, income tax,
fringe benefits tax, and cash bidding payments
∙ undeducted exploration
expenditure incurred on or after 1 July 1990 can be transferred to
other projects subject to conditions, and
∙ assessable receipts include the amounts
received from the sale of all petroleum (or a marketable petroleum
commodity) (Division 2 of Part V).(3)
Projects incurring the PRRT are not subject to crude oil excise
or royalties. Being a tax on profits, the PRRT does not affect
petrol pump prices. About 24 companies pay the PRRT.(4)
In 2004-05, revenue from the PRRT was $1.465
On 10 May 2005, the Government announced, in the context of the
2005 06 Budget, that it proposed to amend the PRRT Act to:
allow the deduction of transferable exploration
expenditure when calculating quarterly instalments, and of fringe
benefits tax for PRRT purposes
allow the deduction of closing-down costs when moving from a
production licence to an infrastructure licence
include the PRRT in the self-assessment regime
provide roll-over relief for internal corporate
introduce a transfer notice requirement for vendors disposing of
an interest in a petroleum project, and
extend the lodgement period for PRRT annual returns from 42 days
to 60 days.
The changes would take effect from 1 July
On 25 May 2005, the Australian Petroleum Production and
Exploration Association Limited (APPEA) issued a press release
welcoming the proposed changes.(7)
The main effect would be to encourage companies to close down
facilities when one or more petroleum production licences expire,
and so not extend the facilities economic lives under
Schedule 1 to the Bill amends the PRRT Act to require PRRT
taxpayers to transfer and deduct transferable exploration
expenditure when calculating their PRRT quarterly tax instalment
for each instalment period. The estimated financial consequences
are shown in the following table ($ million).
Source: Explanatory Memorandum, p. 3.
Schedule 2 to the Bill amends the PRRT Act to allow
restructuring within company groups while preserving the ability to
transfer exploration expenditure among petroleum projects of group
companies. The estimated financial consequences are shown in the
following table ($ million).
Source: Explanatory Memorandum, p. 4.
Schedule 5 amends the PRRT Act to:
allow the deductibility of fringe benefits tax for PRRT
introduce a transfer notice requirement for vendors
disposing of an interest in a petroleum project
extend the lodgement period for PRRT annual returns
from 42 days to 60 days, and
introduce a number of unrelated minor technical
The estimated financial consequences are shown in the following
table ($ million).
Fringe benefits tax
Source: Explanatory Memorandum, p. 6.
PRRT is payable in quarterly instalments (the amount paid
quarterly is the notional tax amount ). Undeducted exploration
expenditure incurred on a petroleum project can be transferred to
another petroleum project. However, taxpayers can transfer and
deduct exploration expenditure only at the end of the year.
Consequently, the amounts that taxpayers claim as deductions in
their quarterly returns are understated, so taxpayers overpay PRRT
during the year. In effect, taxpayers provide interest-free loans
to the Australian Taxation Office. While the overpayments are
adjusted at the end of the tax year, taxpayers are not compensated
for the loans.
The ability to transfer undeducted expenditure from one project
to another depends, among other things, on the common ownership
rule. The Explanatory Memorandum notes:
The common ownership rule tests the continuity of
common ownership between the source project incurring the
exploration expenditure (ie, the non-PRRT paying project) and the
receiving project (ie, the PRRT paying project).(9)
Division 3A of Part V and the Schedule to the PRRT Act deal with
transfers of exploration expenditure incurred on or after 1 July
The objective of allowing deductibility of transferable
exploration expenditure when calculating quarterly PRRT instalment
payments is effected through Schedule 1 of the
Petroleum Resource Rent Tax Assessment Amendment Bill 2006 (the
Bill) and primarily through proposed new section 45E
Instalment transfers and annual transfers in item
7. Subsection 45E(1):
obliges PRRT taxpayers to transfer transferable
exploration expenditure in an instalment period in a way that is
consistent with the way end-of-year transfers are made under rules
governing transferability Consequently, instalment transfers must
be made so far as they can be and so far as the expenditure can be
used against what would otherwise be taxable profit. There is an
offence if instalment transfers are not made in that
Deductions that relate directly to a project are deductible in
the year transferable exploration expenditure is incurred.
Paragraph 45E(3)(a) extends this principle to
quarterly expenditure by providing that a quarterly instalment
period is taken to be a financial year. The Explanatory Memorandum
As a result, transferable exploration expenditure
incurred in an instalment period in a year of tax is immediately
deductible in the instalment period the transferable exploration
expenditure is actually incurred.(11)
Any excess of deductible expenditure over assessable receipts
can be carried forward for deduction against future receipts.
all prior year general expenditure and exploration
expenditure incurred before 1 July 1990 is taken account of in
working out an instalment of tax for an instalment
For the purpose of calculating instalments, deductible
expenditures incurred before 1 July 1990 including
compounded expenditures are deductible in percentages: 25 per cent
in the first instalment period, 50 per cent in the second
instalment period and 75 per cent in the third instalment period
[paragraph 45E(3)(b)]. The instalment periods are
1 July to 30 September, 1 July to 31 December, and 1 July to 31
In the case of transferable exploration expenditures that is,
those incurred on or after 1 July 1990
paragraph 45E(3)(c) provides that unused (that is,
not yet deducted) expenditures are also allocated using the same
The ability to transfer exploration expenditure from one project
to another is subject to a common ownership rule. Breaches of the
rule could give rise to situations where taxpayers claim amounts
that exceed those they can legally claim. The resulting excess
transfer reduces the amount of PRRT paid below the amount that is
payable. In effect, the Australian Taxation Office provides an
interest-free loan to the taxpayer. To counter this, the:
Bill introduces a new interest charge, called the
instalment transfer interest charge. The instalment transfer
interest charge is not a penalty. Rather, it recoups
(approximately) the time value of money associated with excess
transfers of exploration expenditure.(14)
Item 10 inserts new section
98A to effect the interest charge. Subsection
98A(1) contains the circumstances under which a liability
to pay an instalment transfer interest charge arises. They are:
where the transfer has been made in accordance with sections 45A
or 45B which deal with the transfer of expenditure
[paragraph 98A(1)(a)], and
an annual transfer cannot be made because of a violation of the
ownership rule [paragraph 98A(1)(b)].
Subsections 98A(2) and 98A(3)
deal with offsets to instalment transfer excesses. Offsets arise in
The first circumstance deals with scenarios
relating to the particular transferable exploration expenditure
relating to the instalment transfer that has been reversed. This
transferable exploration expenditure may be subsequently applied or
transferred in the same year of tax as the original instalment
transfer occurred, and so much of the expenditure as is so applied
or transferred will offset the instalment transfer excess [Schedule
1, item 12, paragraph 98A(2)(a)]. The second circumstance deals
with the possibility of alternative annual transfers offsetting the
instalment transfer excess [Schedule 1, item 12, paragraph
The first circumstance is discussed in paragraphs 1.28 to 1.31
of the Explanatory Memorandum, and the second circumstance in
The Government s proposals to introduce roll-over relief for
taxpayers undergoing internal corporate restructuring are contained
in Schedule 2. As noted, undeducted exploration expenditure
incurred on or after 1 July 1990 can be transferred to other
This regime allows and requires exploration
expenditure actually incurred on a particular petroleum project
which is not absorbed against assessable receipts from this project
(ie, a project not generating a PRRT liability) to be transferred
to the extent it can be offset against assessable receipts of
another petroleum project (ie, a project generating a PRRT
liability). The ability to transfer exploration expenditure between
projects in this way is dependent on meeting the common ownership
The PRRT Act requires a company that has unused transferable
expenditure the loss company to transfer this expenditure to
another company the profit company if both companies are members of
the same group of companies, that is, an intra-group transfer. This
requirement is subject to the condition that there must be
continuity of ownership of both companies. Clause 31 of the
Schedule to the PRRT Act contains the continuity of ownership test.
An effect of clause 31 is to prevent transfers of
exploration expenditure where the company with an interest in
either the transferring or receiving project has changed since the
exploration expenditure was incurred, even if both the interests
have remained at all times within a common company group. That is,
it does not allow internal corporate restructures to occur without
losing the ability to transfer exploration expenditure sometime in
According to the Minister s second reading speech:
This taxation distortion results in company groups
maintaining inactive companies, merely to protect their future
ability to transfer unused exploration expenditure.
The purpose of the amendments in the Bill is:
to allow internal corporate restructuring of a
wholly-owned group to occur without losing the ability to transfer
unused exploration expenditure.(18)
Item 2 repeals clause 31 of the Schedule and
inserts a new clause 31 Rule continuity of interest within
company group. The main rule is in subclause
31(1). This provides:
the company that received the transfer (the receiving
interest company) and the company that held the loss that was
transferred to the receiving company, must belong to the same
both companies must be group members for the entire
period from the start of the financial year in which the
expenditure was incurred until the end of the year in which the
transfer was effected, and
it was the loss company that actually incurred the
One of the Government s proposals was to allow deductibility of
project closing-down costs when converting a production licence to
an infrastructure licence. The Explanatory Memorandum contains the
following background on infrastructure licences:
Infrastructure licences were introduced through an
amendment to the Petroleum (Submerged Lands) Act 1967 in 2000.
Infrastructure licences are granted to allow the use of petroleum
infrastructure facilities in Commonwealth (offshore) waters for
specified activities. A typical example is where the petroleum
reserves for a project have been exhausted and rather than close
down the project infrastructure related to this reserve, an
infrastructure licence is granted to process petroleum piped in
from an alternative source located nearby. The owners of the
infrastructure would receive a fee for providing this service to a
third party. (19)
The effect of infrastructure licences is to extend the economic
life of offshore petroleum project facilities.
The taxation treatment of the cost of closing down facilities
differs depending on whether the project is closed down under a
petroleum production project licence or under an infrastructure
Petroleum projects are likely to have substantial
expenditures on closing down the project, including associated
environmental restoration costs. These costs are part of deductible
expenditure for Petroleum Resource Rent Tax (PRRT) purposes.
However, some project facilities may go on to non-project use under
an infrastructure licence. When project facilities stop being used
for the project, but remain in use, any later costs of closing down
their use under the infrastructure licence are currently not
recognised (either directly or indirectly) for PRRT
The reason for this treatment is:
closing down expenditures are currently not
included in closing down expenditure for the particular petroleum
project because they relate to closing down the activities under
the infrastructure licence rather than under the production
The Bill proposes treating closing-down costs incurred under
infrastructure licences as deductible expenditure for PRRT
Schedule 3 to this Bill amends the Petroleum
Resource Rent Tax Assessment Act 1987 (PRRT Act) to allow the
present value of expected future expenditures associated with
closing down petroleum project assets that continue to be used
under an infrastructure licence to be deductible against the PRRT
receipts of this project. This change is made so far as these costs
are currently not recognised for PRRT purposes.(22)
Item 5 inserts a new section 2D Future
closing-down expenditure. Section 2D defines the
circumstances under which a taxpayer is considered to have future
closing-down expenditure. They are:
the project ceases to be a petroleum project because one or more
of its production licences have expired [paragraph
an infrastructure licence has comes into effect, which allows
the continued use of the facilities [paragraph
had the facilities not been used under an infrastructure
licence, the taxpayer would have incurred closing-down costs
New subsection 2D(2), among other things,
defines future closing-down costs . They are the payments whether
of a capital or revenue nature that the taxpayer or another person
who is responsible for closing down the facilities would expect to
incur in closing the facilities. The definition specifically
includes environmental restoration.
Net present value is a way of converting future costs into today
s dollars. Discounting is the technique used to make the
conversion. Discounting recognises that a dollar today is not the
same thing as a dollar in the future because today s dollar can be
invested. Subsection 2D(2) contains the formula used to obtain the
net present value of future closing-down expenditure. The discount
rate is 1.02 plus the long-term bond rate. Because the latter
fluctuates, subsection 2D(2) defines the long-term bond rate as the
rate in relation to the financial year when the project ceases.
Presumably this means an average of the rate over the period in the
financial year before the day when the project ceases.
Section 39 of the PRRT Act deals with closing-down expenditure.
Item 8 inserts three new
subsections: subsection 39(2),
subsection 39(3) and subsection
39(4). Subsection 39(2) deals with situations where the
taxpayer disposes of the petroleum project facility at the end of
the project (and had incurred deductible expenditure on the
project), makes a payment to the new owner which relates to future
closing-down expenditure, then that payment is considered to be
part of the closing down costs the taxpayer incurred. Subsection
39(2) is further explained in paragraph 3.17 of the Explanatory
Memorandum (including an example).
Subsection 39(4) prevents double counting by providing that
where a taxpayer has future closing-down expenditure, that
expenditure is reduced by any actual closing-down expenditure.
As noted, on 10 May 2005, the Government announced that it
proposed to include the PRRT in the self-assessment regime.
Self-assessment is through the mechanism of a deemed
assessment.(23) A deemed assessment arises when the
taxpayer lodges a return and the Commissioner is deemed to have
made an assessment of the tax in the return. This does not, of
course, prevent the Commissioner from reviewing the return. If, on
review, the Commissioner determines that the taxpayer has paid less
tax than was legally payable, in addition to paying the shortfall,
the taxpayer has to pay interest on the shortfall the shortfall
The Explanatory Memorandum contains the following comparison of
the key features of the proposed new law and the current law.
At the time a PRRT
taxpayer lodges a return, the Commissioner is deemed to have made
PRRT taxpayers lodge an
annual return and the Commissioner makes an assessment of how much
tax is payable. The Commissioner then issues a notice and taxpayers
have 21 days to pay any tax due.
The standard four-year
period of amendment of a PRRT assessment is introduced. The
unlimited amendment period in the case of fraud or evasion and
other limited circumstances remains.
The Commissioner has three
years to amend an assessment if there is avoidance of tax but full
and true disclosure of all material facts necessary for an
assessment. The amendment period is extended to six years if the
taxpayer fails to make a full and true disclosure of all material
facts necessary for an assessment. There is no time limit on
amending assessments in the case of fraud or evasion and other
The shortfall interest
charge will apply to shortfalls of PRRT. The general interest
charge will apply to amounts not paid by the due date.
The general interest
charge applies where the amendment of assessment results in an
increased PRRT liability.
PRRT taxpayers will have
access to the same rulings regime as income taxpayers. In the case
of PRRT taxpayers, the Commissioner may provide advice in the form
of a public and private ruling.
The Commissioner cannot
provide private rulings on PRRT matters. The Commissioner can
provide administratively binding rulings, but is not legally bound
to provide this advice when making an assessment of PRRT
Source: Explanatory Memorandum, p. 50.
To effect the change to self assessment, item
10 repeals Division 2 of Part VI of the PRRT Act and
substitutes a new Division 2. New section
62 provides that where a person has lodged a return with
the Commissioner and the Commissioner has not previously issued an
assessment to the taxpayer [subsection 62(1)], the
Commissioner is deemed to have made an assessment of the amount of
the person s taxable profit (including that the person does not
have to pay tax) [subsection 62(2)].
Subsection 62(3) provides that the assessment is
deemed to have been made on the day when the return is given to the
Commissioner. Subsection 62(4) provides that on
the day and after the day the Commissioner is deemed to have made
an assessment, the return is taken to be a notice of the
Item 10 also inserts new section 67 Amendment of
assessment. Subsection 67(1) provides
that the Commissioner may amend an assessment within four years
after the day on which the notice of assessment was given to the
With respect to rulings:
Currently, PRRT taxpayers can receive
administratively binding advice from the Commissioner. However,
they do not currently have access to the legally binding public or
private rulings system, and have no access to the system of appeal
and review in relation to legally binding
The Bill proposes that:
PRRT taxpayers will be provided access to the
provisions dealing with ATO advice in the same way as these
provisions apply in the income tax context.(26)
Item 37 amends the Taxation Administration
Act 1953 (TAA 1953) by inserting new subparagraph
(fa) after paragraph 357-55(f) in Schedule 1. This
also enables PRRT taxpayers to obtain binding
rulings from the Commissioner in exactly the same way as income
taxpayers. This is done by adding PRRT to the list of taxes the
rulings provisions in the TAA 1953 apply to.(27)
As noted, the Government undertook to allow deductibility of
fringe benefits tax for PRRT purposes. Another proposal was to
introduce a transfer notice requirement for vendors disposing of an
interest in a petroleum project.
Paragraph 5.11 of the Explanatory Memorandum hints at the reason
for the decision to allow deductibility of fringe benefits tax. The
PRRT Act excludes indirect expenditure from deductible expenditure.
What constitutes direct and indirect expenditure is now subject to
dispute with the Australian Taxation Office.(28)
Section 48 of the PRRT Act deals with the transfer of an entire
entitlement to assessable receipts, while section 48A deals with
the transfer, on or after 1 July 1993, of part of an entitlement to
assessable receipts. The Explanatory Memorandum elaborates:
Sections 48 and 48A of the PRRT Act contain rules
on the treatment of parties when there is a transfer of an interest
in a petroleum project from one party (the vendor) to another (the
purchaser). The effect of these two sections is to place the
purchaser in the same position in relation to the petroleum project
as the vendor (though not in the same position in relation to wider
deductibility of past project expenditure). It treats the purchaser
as if they had derived assessable receipts, incurred deductible
expenditure and paid tax instalments of the vendor in relation to
that interest in the petroleum project up to the time of the
transaction, and treats the vendor as not having done
The reasons for introducing the transfer notice are as
There is currently no requirement under the PRRT
Act which requires the vendor, when selling their interest in a
petroleum project, to provide a transfer notice containing
information about assessable receipts derived or expenditure
incurred, or other relevant information, in relation to the
project. In particular, there is a concern that the purchaser may
not be aware of the amount of deductible expenditure incurred by
the vendor up to the time of the transaction. To the extent that
such expenditure may have been transferred to other projects, or to
other taxpayers, under the wider deductibility provisions, the
purchaser is especially likely to depend in practice on information
from the vendor even where some of the information may otherwise be
able to be inferred, such as from records of a wider joint
The Explanatory Memorandum contains a comparison of the key
features of the new law and the current law.
Payments of fringe benefits
tax are not included in the list of excluded expenditures for PRRT
purposes. As a result, such payments may be deductible for PRRT
purposes subject to other requirements specified in the PRRT
Payments of fringe benefits
tax are excluded expenditure (ie, non-deductible) for PRRT
The vendor must provide
written notice in the approved form to the purchaser within 60 days
after entering into the transaction, or within 60 days after the
purchasers give consideration for entitlement and property,
whichever is the latest.
There is no requirement for
a written notice from the vendor disposing of an interest in a
The time period to lodge a
PRRT annual return is 60 days.
The time period to lodge a
PRRT annual return is 42 days.
Source: Explanatory Memorandum, p. 63.
Section 44 of the PRRT Act deals with excluded expenditure ,
that is, expenditure excluded for the purposes of determining what
constitutes deductible expenditure. Subsection 44(h) excludes
payments of tax under the Fringe Benefits Tax Assessment Act
1986. Item 8 amends paragraph 44(h) by
omitting the Income Tax Assessment Act 1997 or the
Fringe Benefits Tax Assessment Act 1986 and substituting
or the Income Tax Assessment Act 1997 .
Item 13 amends section 48 by adding new
subsection 48(3), which requires the vendor to give
written notice of the transaction, in the approved form, to each
purchaser within 60 days after entering into the transaction, or
within 60 days after the purchaser gives consideration for
entitlement and property, whichever is the later.
The Bill gives effect to all the Government s proposals with
respect to the PRRT regime. The proposal to allow the present value
of expected future closing-down expenditures to be deductible
against the PRRT where project facilities subject to infrastructure
licences are closed down, seeks to address the apparent
inconsistency in existing law under which closing-down costs are a
deductible expense for PRRT purposes when part of a petroleum
project licence but not when the facilities are subsequently
operated under an infrastructure licence. A question that arises is
how future closing-down costs will be estimated.
The concept of being able to claim future expenses for taxation
purposes differs from the usual principle that the taxpayer must
have actually incurred expenditure to be able to claim a deduction.
The use of estimated expenses is, however, not new to taxation law.
Depreciation costs allowed as a deduction in any one year are, in
effect, estimated costs. However, in this case, when assets are
sold, there are provisions that take account of underestimation or
overestimation of depreciation over the asset s life, and the costs
of disposal are deductible. The possibility of over-claiming future
closing-down costs may be covered by the anti-avoidance provisions
of Division 6 of the PRRT Act.
It could be argued the current taxation treatment whereby
closing-down costs under an infrastructure licence are not a
deduction for PRRT purposes should stand precisely because they
relate to the infrastructure licence and not the production
licence. In other words, once an infrastructure licence has been
issued, the facilities are no longer part of the petroleum licence
project. On the other hand, it could be argued that since the
facilities were constructed first and foremost as part of a
petroleum project and only secondarily for other purposes under an
infrastructure licence excluding closing-down costs under an
infrastructure licence gives rise to an anomaly.
Finally, it is important to distinguish between any discussion
about what the appropriate taxation treatment should be and the
likelihood that the Bill s proposal will provide an incentive to
extend the effective life of production facilities as
Department of Industry, Tourism and Resources website at
Australian Petroleum Production and Exploration Association
Limited web site at
Accessed 29 May 2006.
Adapted from ibid.
Elizabeth Kazi, ATO faces challenge over PRRT Australian
Financial Review, 16 December 2005.
Final Budget Outcome 2004-05, p. 3.
Hon. Peter Costello (Treasurer) and Hon. Ian MacFarlane
(Minister for Industry, Tourism and Resources), Policy
modifications to the petroleum resource rent tax and the proposed
gas transfer price regulations, joint press release no. 054,
10 May 2005, at
Accessed 29 May 2005.
Australian Petroleum Production and Exploration Association
Limited, petroleum Resource Rent tax changes welcomed by
upstream oil & gas industry, media release, 25 May 2006 at
Accessed 29 May 2006.
Explanatory Memorandum, p. 6.
Explanatory Memorandum, paragraph 1.5, p. 10.
Explanatory Memorandum, paragraph 1.13, p. 13.
Explanatory Memorandum, paragraph 1.14, p. 13.
Explanatory Memorandum, paragraph 1.23, p. 15.
Explanatory Memorandum, paragraph 1.5, p. 10.
Explanatory Memorandum, paragraph 1.27, p. 16.
Explanatory Memorandum, paragraph 2.3, p. 25.
Explanatory Memorandum, paragraph 2.7, p. 27.
Explanatory Memorandum, paragraph 2.9, p. 28.
Explanatory Memorandum, paragraph 3.21, p. 42.
Explanatory Memorandum, paragraph 3.1, p. 35.
Explanatory Memorandum, paragraph 3.8, p. 37.
Explanatory Memorandum, paragraph 3.2, p. 35.
Explanatory Memorandum, paragraph 4.18, p. 52.
Explanatory Memorandum, paragraph 4.8, p. 48.
Explanatory Memorandum, paragraph 4.5, p. 48.
Explanatory Memorandum, paragraph 4.12, p. 49.
Explanatory Memorandum, paragraph 4.51, p. 59.
Elizabeth Kazi, op. cit.
Explanatory Memorandum, paragraph 5.5, p. 62.
Explanatory Memorandum, paragraph 5.6, p. 62.
Richard Webb and Bernard Pulle
15 June 2006
Bills Digest Service
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