Dandy Producing Company Limited operates in both onshore and offshore in the riverine areas in Nigeria. It has been in the oil prospecting business for many years.

The company applied for and was granted a petroleum prospecting licence (PPL) on January 1, 2023 after studying the provisions of the Petroleum Industry Act, 2021.

The company’s financial records for the year ended December 31, 2023 are as follows:

Revenue earned: N’million N’million
Value of crude oil sold 486,000
Value of condensate from associated gas sold 128,000
Value of natural gas liquid from associated gas sold 112,500
Income from refinery operations 25,100
Gross revenue 751,600
Expenses deducted:
Production cost 330,400
Cost of gas reinjection wells 1,600
Drilling cost incurred 6,650
Depreciation of plant, machinery and fixtures 2,010
Decommissioning and abandonment cost 2,500
Repairs and maintenance 4,200
Royalty cost incurred and paid 171,500
Niger Delta Development Commission charge 340
Finance cost and bank charges 615
Terminaling cost 2,345
Donations to approved charity homes 195
Concession rentals 74,110
Host community fund 23,200
Local government municipal levy 250
Environmental remediation fund 2,800
Cost incurred in seeking information for oil deposits 540 623,255
Net profit 128,345

Additional information made available:

(i) Losses brought forward from previous year was N380 million.

(ii) Repairs and maintenance:

N’million
Repairs of plant and machinery 970
Repairs or alteration of production utensils 3,230
4,200

(iii) Drilling cost incurred comprised:

N’million
Tangible drilling cost for first exploration well 3,990
Drilling of the first two appraisal wells 2,660
6,650

(iv) Production allowance after commencement of the Petroleum Industry Act, 2021 amounted to N6,401 million.

(v) Capital allowances computed and agreed:

N’million
– For the current year 2,750
– Unrecouped brought forward 1,350
4,100

(vi) Exchange rate agreed with the CBN was N752 to a USD ($).

Required: As a newly qualified accountant just appointed by the company as its Tax Consultant, compute hydrocarbon tax in line with the provisions of Petroleum Industry Act, 2021.

Dandy Producing Company Limited

Computation of hydrocarbon tax

For 2023 assessment year

N’million N’million
Revenue
Value of crude oil sold 486,000
Value of condensate from associated gas sold 128,000
Value of natural gas liquid from associated gas 112,500
Gross revenue 726,500
Balancing charge Nil
Total income 726,500
Allowed deductions (Section 263)
Production cost 330,400
Cost of gas reinjection wells 1,600
Drilling cost 6,650
Decommissioning and abandonment 2.500
Repairs and maintenance 4,200
Royalties cost incurred and paid 171,500
NDDC charge 340
Terminaling cost 2,345
Concession rentals 74,110
Host community fund 23,200
Local government municipal levy 250
Environmental remediation fund 2,800
Total allowable deductions (S.263) 619,895 (619,895)
Total costs subject to CPR limit (W1) 623,995
Excess allowable cost carried forward NIL
Adjusted profit 106,605
Less: Loss relief (380)
Assessable profit 106,225
Less: Section 266 and 6th schedule deductions
Capital allowance for the year 2,750
Unrecouped b/f 1,350 (4,100)
102,125
Less: production allowance (6,401)
chargeable profit 95,724
Hydrocarbon tax@15% od N95,724 14,358.6

Workings

  1. Cost –price –ratio (CPR) limit
N’ million N’million
a. Gross revenue 726,500
I Maximun allowable @65% on gross revenue of N726,500 472,225
Total operating cost 619,895
Capital allowances 4,100
b. Total eligible costs 623,995
Less: Exempted cost incurred [(section 263 (1)]
Royalties paid 171,500
NDDC Charge 340
Concession rentals 74,110
Host community fund 23,200
Environmental remediation fund 2,800
ci. Total exempted cost (271,950)
ii =B-C1=Net total costs to be subject to CPR 352,045
C2 Maximum allowable cost is the lower of (i) and (ii) Which is N352,045 million
D. Total allowable cost ( in line with the Practice of FIRS) =C1+C2 ( that is , Exempted cost +CPR restricted cost) =N271,950 million + N352, 045 million =N623,995 million

Note: We sincerely believe that capital allowances should not have been added to total operating cost in determining the total eligible costs in the computation of CPR limit. But in this situation, we adhered strictly to the format of FIRS, being the Federal tax administration.

Henceforth, candidates are advised to adhered to this format (FIRS circular), pending any subsequent review of the same.

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