- 20 Marks
OGMT – Feb 2020 – L1 – Q4 – Assignment of Petroleum Rights
Explain the tax treatment of assignment or disposal of petroleum rights under the Income Tax Act, 2015 (Act 896).
Question
a) Explain the tax treatment of assignment of or disposal of petroleum rights as provided under the Income Tax Act 2016 (Act 896).
b) Deep Sea Ventures and Coastal Explorations are joint venture partners who have 45% and 40% interest respectively in the Atlantic Oil Fields in Ghana. They commenced exploration in 2010 and discovered hydrocarbons in commercial quantities in 2015. A plan of development was subsequently approved for the development of the Atlantic Oil Fields.
The fiscal terms of the agreement between the joint venture partners and the Government of Ghana include Bonus of US$ 100 million, Royalty of 10%, Initial (Carried) Interest of 10% Additional Participating Interest of 5%, Corporate Tax rate of 35% and Capital Allowance on straight line basis at a rate of 20%. Commercial production commenced in the Atlantic Oil Fields in 2019. Information available on the oil and gas production operations in the Atlantic Oil Fields are as follows:
Up to 31/12/2017 | US$ |
---|---|
Exploration Costs | 250,000,000.00 |
Development Costs | 2,000,000,000.00 |
Bonus | 100,000,000.00 |
As at 31/12/2018 | US$ |
---|---|
Exploration Costs | 15,000,000.00 |
Development Costs | 1,500,000,000.00 |
Interest on loan for installations & infrastructure | 100,000,000.00 |
NB. The loan was contracted by the operator on behalf of the parties that hold interest in the Atlantic Oil Fields
As at 31/12/2019 | US$ |
---|---|
Exploration Costs | 5,000,000.00 |
Development Costs | 430,000,000.00 |
Required: Compute the capital allowance entitlements of Deep Sea Ventures and Coastal Explorations and state the underlying assumptions for your computations.
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