Energy and Resources Point-in-Time Service Updates

The Energy and Resources Point-in-Time Service has been updated to include the Petroleum Resource Rent Tax Assessment Regulations 2024 (Cth).

Petroleum Resource Rent Tax Assessment Regulations 2024

These Regulations repeal and remake the Petroleum Resource Rent Tax Assessment Regulation 2015 (Cth) (the 2015 Regulations), which were due to sunset on 1 April 2026. The Regulations make various minor changes to update the drafting of the 2015 Regulations, as well as substantive changes that align with the Treasury Gas Transfer Pricing Review, including:

• various changes to better accommodate commercial tolling arrangements;
• requiring an irrevocable election to be made to use either the shorter or longer asset life formula;
• equalising the treatment of the notional upstream and downstream entities between loss and profit situations when using the residual pricing method (RPM);
• updating the comparable uncontrolled price rules to align with current guidelines from the Organisation of Economic Cooperation and Development;
• modifying the advanced pricing arrangement rules (APA) to provide additional guidance to both industry and the Commissioner of Taxation on the principles to consider in agreeing to an APA;
• ensuring that when a new facility is brought into the Petroleum Resource Rent Tax regime for the first time, that the value of the plant for use in the RPM is the historical cost of the facility.

The new amendments have been updated in the Point-in-Time Energy and Resources Service current to 8 August 2024. (NB: Subscription required).

If you are not already a subscriber to this or other Point-in-Time Services then please contact us to find out more or to take a free trial.