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Tolley's International Taxation of Upstream Oil and Gas 2nd ed

John Abrahamson

ISBN13: 9780754555421

New Edition ISBN: 9780754558118

Previous Edition ISBN: 9780754550099

Published: December 2017

Publisher: LexisNexis Butterworths

Country of Publication: UK

Format: Paperback

Price: Out of print

The scope of this title is to introduce and review significant international tax issues for upstream oil and gas operations.

The book is based on introducing and explaining practical upstream tax issues, with an emphasis on tax risk management and related tax planning. Readers will develop skills in identifying tax exposures and opportunities, managing tax negotiations, and applying tax planning solutions.

The book is intended to benefit accountants, lawyers, economists, financial managers and government officials. The book aims to be the first choice for the new starter in upstream oil and gas taxation.

It also aims to be the best introduction of international tax issues relating to upstream oil and gas, enabling the reader to analyse and understand new situations and circumstances, rather than an encyclopaedic reference of tax issues.

Subjects:: Taxation, Energy and Natural Resources Law

Contents:: Chapter I. Introduction; 1. Upstream Oil and Gas - Background; 2. Oil and Gas Producing Countries; 3. Largest Upstream Companies; 4. Largest Service Providers; Chapter II. International Tax; 1. Introduction; 2. International Investment; 3. International Income Flows; 4. Transfer Pricing; 5. Domestic Tax Laws; 6. Tax Treaties; Chapter III - Tax Regimes; 1. Concession Regimes Tax and Royalties; 2. Production Sharing Contracts Profit and Cost Oil; 3. Service Contract Regimes; 4. Royalties; 5. Production and Signature Bonuses; 6. Area Rentals; 7. State Equity and Carried Interests; 8. Excise Tax; 9. Indirect Taxes - VAT and State taxes; Chapter IV - Country Tax Regimes - Examples and Selected Issues; 1. Introduction; 2. Algeria; 3. Angola; 4. Australia; 5. Brazil; 6. Canada; 7. Denmark; 8. Greenland; 9. Kazakhstan; 10. Mexico; 11. Nigeria; 12. Norway; 13. Qatar; 14. Saudi Arabia; 15. United Kingdom; 16. United States; Chapter V - Tax Rate Increases and Bilateral Investment Treaties; Chapter VI - Foreign Exploration Losses; Chapter VII - Oil and Gas Operations and Permanent Establishments; 1. Permanent Establishments; 2. Contracting Services; 3. External Consortium; 4. Tripartite Agreements; 5. Tax Grossing Up; 6. Recovery if Withholding credited; Chapter VIII - Capital Gains; 1. Holding Companies; 2. Treaty protection; 3. Tax Treaty Example - Netherlands; 4. Tax Treaties and Indirect Transfers - Australia; Chapter IX - Mergers and Acquisitions; 1. Acquire Assets or Target Company; 2. Interest Deductions - Debt Push Down; 3. Depreciation and Asset Step Up; 4. Tax Losses; 5. Merger Relief; 6. Sale and Purchase Agreements; 7. M&A Issues to Review; 8. Seller Warranties; 9. Seller imposing tax on Purchaser - Grossing Up; 10. Buyer Protection - Indemnity Clause; 11. Tax Due Diligence; 12. Buyers Information Request List; 13. Input to Financial Modelling; 14. Accounts and Deferred Tax Balances; Chapter X - Intellectual Property; 1. Oil and Gas IP Structures; 2. Switzerland; 3. Netherlands; 4. Luxembourg; 5. United Kingdom; 6. Brazil; Chapter XI - Leasing; 1. Introduction; 2. Operating Leasing and Permanent Establishments; 3. Sale and Leaseback; 4. Singapore Example; 5. Specific Assets; 6. Tax Treaties - Leasing into the USA; Chapter XII - Decommissioning; Chapter XIII - Oil and Gas Financing; 1. Introduction; 2. Group treasury centres and In-house banking; 3. Thin capitalization; 4. Controlled Foreign Corporation (Subpart F); 5. Hybrid Entities and Hybrid Securities; 6. Sale and Repurchase (Repo) - USA and UK; 7. Interest on Share Equity - Brazil; 8. Limited Partnership - China; Chapter XIV - Profit Repatriation and Planning; 1. Branches and Head Office Costs; 2. Subsidiaries and Dividends; 3. Capital Gains; 4. Technical Service and Administration Fees; Chapter XV - Procurement; 1. Planning Structures; 2. Netherlands, Hong Kong and Singapore; Chapter XVI - Oil and Gas Trading; 1. Planning Structures; 2. Derivatives - Options, Forwards and Swaps; 3. Switzerland; Chapter XVII - Transfer Pricing Concepts; 1. OECD and UN approaches; 2. Branch Profit Allocation; 3. Defence Files and Audit; 4. TP and Tax Treaties; 5. Advance Pricing Agreements (APAs); Chapter XVIII - Transfer Pricing and Upstream Oil and Gas; 1. Oil and Gas Sales; 2. Seismic Surveys; 3. Drilling; 4. Financial and Environmental Guarantees; 5. Transfer Pricing and Procurement; 6. Transfer Pricing and Oil and Gas Trading; Chapter XIX - Transfer Pricing and Intellectual Property (IP); 1. Intellectual Property in Oil and Gas; 2. Royalties or Cost Sharing; 3. Performance Based Royalties; Chapter XX - Transfer Pricing and Administration; 1. Allocating Costs - Including Finance, IT, HR, and Legal; 2. Branch Issues, including capital allocation; Chapter XXI - Transfer Pricing and Financing Structures; Case Studies; I. Tax Treaties and Permanent Establishments - Equipment; II. Tax Treaties and Permanent Establishments - Exploration and Drilling; III. Mergers & Acquisitions - Structuring - Brazil; IV. Mergers & Acquisitions - Due Diligence - Canada; V. Transfer Pricing - Drilling Products; VI. Transfer Pricing - Intellectual Property - USA Oil Co and the IRS