Date post: | 25-May-2015 |
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FISCAL SYSTEM
A Joint Venture Must Consider
ECONOMIC RENT
Difference between the value of production and the cost to extract it
EXTRACTION COSTS
Includes normal exploration,development and operating costs as well as required rates of return or share of profit for the contractor
GOVERNMENT POINT OF VIEW
TRADE - OFF
BETWEEN
Risk Aversion
Risk Sharing
Leaning towards bonus bids and royalties
Production or profit sharing through taxation schemes
PERCENTAGE OF COUNTRIES THAT USESignature Bonuses 40 %
Royalties 75 % 1/3 of them are slidingOf the flat ones, 2/3 are less than 12.5%World Average is 7 %
Government Participation
50 % Average workinginterest participation is 30% for those countries with the participation option
Profit –based Mechanisms Taxes P/O Splits
90%
50%
75% are direct25% are deemed paid or in lieu1/3 have additional taxes
85% of these are sliding
Other 25 % have withholding taxes7 % have DMOs
DIVISION OF REVENUES
TAX BASE SPECTRUM
ROYALTY/TAX SYSTEMSFIRST - ROYALTY
AS % OF GROSS REVENUE
SECOND – DEDUCTIONS
OPERATING COSTS, DD& A AND IDCs
THIRD – TAXATIONS
TAXABLE INCOME (REVENUE LESS ROYALTY AND DEDUCTIONS)SUBJECT TO ONE OR MORE LAYERS OF TAXATION
CONCESSIONARY SYSTEM FLOW DIAGRAM One Barrel of Oil " Full Cycle " Gross Revenue
Contractor $20 Government Share Royalty Share 12.50% $2.50 $17.50 Net Revenue $5.65 Deductions
Assumed cost Capex and Opex $11.85 Taxable Income
Special Petroleum Tax $2.96 25% $8.89 Income Tax Rate $3.11 $5.78 35% $11.43 Division of Gross Revenues $8.57
$5.78 Division of Cash Flow $8.57 40% TAKE 60%
$5.78/($20-5.65) $8.57/($20-5.65)
87.5% Lifting Entitlement 12.5% $17.50/$20 $2.50/$20
BASIC EQUATIONS, ROYALTY/TAX SYSTEMSGross Revenues = Total oil and gas revenuesNet Revenues = Gross Revenues
( - ) RoyaltiesNet Revenue ( % ) 100% minus Royalty rate ( % )
Taxable Income = Gross Revenues( - ) Royalties
DEDUCTIONS
( - ) Operating costs( - ) Intangible capital costs (1)( - ) DD&A ( including abandonment costs)( - ) Investment credits ( if allowed)( - ) Interest on Financing ( if allowed)( - ) Tax loss carry forward( - ) Bonuses (2)
Net Cash Flow = Gross Revenues( after tax) ( - ) Royalties
( - ) Tangible capital costs( - ) Intangible capital costs (1)( - ) Operating costs( - ) Bonuses( - ) Taxes
(1)In many systems no distinction is made between operating costs and intangible capital costs, both are expensed.(2) Bonuses are not always deductible for tax calculation purposes.
CONTRACTUAL SYSTEMSFIRST - ROYALTY
AS % OF GROSS REVENUE
SECOND – COST RECOVERY OPERATING COSTS, DD& A AND IDCs
(SUBJECT TO LIMIT SAY 40% OF GROSS REVENUE)
THIRD – PROFIT OIL OR PROFIT GAS SPLIT(REVENUE LESS ROYALTY AND COST RECOVERY)
( SUBJECT TO SPLIT SAY 40% / 60%)
FOURTH – TAXESCONTRACTOR’S SHARE OF PROFIT IS SUBJECT TO TAX