Jaga Petroleum Limited was granted an oil mining lease (OML) in January 2001 for exploration of oil and gas in onshore and shallow water operations for twenty years and a further renewal of twenty years, if application is made.

At the expiration of the initial license on December 31, 2020, the company decided not to apply for an extension of its current license under the Petroleum Profit Tax regime and opted for automatic conversion on January 1, 2021, to the petroleum mining lease (PML) as enshrined in the Petroleum Industry Act 2021.

The following details were extracted from the financial statements of the company for the year ended December 31, 2021:

(i) Revenue:

Category Type Quantity (MB) Actual Price ($) Fiscal Price ($)
Crude oil sold Bonny light 7.5 75 77
Crude oil sold Forcados medium 5.2 69 70
Condensate from associated gas sold ABC condensate 4.0 55 54
Gas liquid from associated gas sold XYZ liquid 3.8 48 50

(ii) Expenses/Expenditure:

Item N’million
Royalty incurred and paid for 118,900
Production cost 112,660
Concession rentals 25,200
Repairs of plant, machinery, and fixtures 2,680
First exploration well costs 2,770
Repairs of production implement utensils 1,850
Cost of gas reinjection wells 1,250
NDDC charge 200
Purchase of information on existence of petroleum deposits 305
Customs duties 106
First two appraisal wells costs 3,900
Decommissioning and abandonment 1,500
Depreciation 2,820
Environmental remediation fund 1,800
State government ground rent fee 22
Finance costs 25
Host community costs 1,400
Miscellaneous expenses 1,129
Administrative costs 1,980

The following additional information was also made available:

(iii) First two appraisal wells costs consisted of 60% tangible costs and 40% intangible costs.
(iv) Expenditure for the purchase of information on existence of petroleum deposits included:

Item N’million
Acquisition of geophysical information 100
Geological data and information 120
Others 85
Total 305

(v) Miscellaneous expenses were:

Item N’million
Gas flare fee 720
Donations to orphanage homes 132
Terminalling cost 169
Stamp duty 18
Signature bonus paid for petroleum deposits 90
Total 1,129

(vi) Agreed capital allowances for the year was N4,500 million.
(vii) Production allowances after commencement of the Act:

Operation Type N’million
Onshore operations 800
Shallow water operations 1,100

(viii) Assume N440 is equivalent to US $1, and tax liabilities payable will be in local currency (Naira).


Required:

Compute for the relevant assessment year the company’s:

  1. Hydrocarbon tax liability (16 Marks)
  2. Companies income tax liabilities (4 Marks)

(a) Jaga Petroleum Limited
Computation of hydrocarbon tax liability
For 2022 assessment year

Workings on cost price ratio

(b) Jaga Petroleum Limited
Companies income tax liabilities
For 2022 assessment year