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Petroleum Profits Tax Act , Cap 13 LFN 2004 Deep

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Title: Petroleum Profits Tax Act , Cap 13 LFN 2004 Deep


1
TAX PRACTICE SECTORTOPICPetroleum Industry
Legislation Tax Issues and Challenges
THE INSTITUTE OF CHARTERED ACCOUNTANTS OF
NIGERIA ..(Established by Act of Parliament
No 15 of 1965)
  • By
  • ALATOYE, Folorunso Azeez, FCA
  • Partner /Chief Operations Officer
  • Saffron Professional Services

2
Objective of Presentation
  • At the end of this session, participants should
    be able to
  • Identify the tax regulations in the petroleum
    industry
  • Discuss the need for the reform
  • Recognise the changing Structure,
  • expectations of the key stakeholders and
  • Appraise the business impact of the reform.

3
Contents
  • Overview of the Nigerian Oil Gas industry
  • Tax Reform in the Petroleum Industry
  • National Oil Gas Policy
  • The Petroleum Industry Bill (Act)
  • The Implication of reforms on foreign investment
    and government revenue
  • Opportunities and Challenges of implementing the
    fiscal provisions
  • Case study
  • Conclusion

4
Overview of the Nigerian Oil Gas industry
  • Oil and Gas Industry sectors
  • Upstream
  • Exploration
  • Production
  • Midstream
  • Refining
  • Downstream
  • Retail
  • This session will focus on upstream oil and gas
    industry.

5
Overview of the Nigerian Oil Gas industry
  • 283 trillion standard cubic feet of proven gas
    reserves in custody only 25billion barrels of
    oil to become 40b barrels by 2010!
  • Africa in all has 500 trillion standard cubic ft.
    against Europe North America Reserve of 450
    trillion standard cubic ft.
  • 65 trillion standard cubic feet of recoverable
    undiscovered reserves
  • 3rd largest exporter of Liquefied Natural Gas
    (LNG) in the world
  • 12th largest major gas reserve country in world
  • By 2015, Nigeria/WA to supply 1.8 trillion scf.
    to U.S 1/3rd of its import needs
  • The 7 billion Nigeria-Algeria (NIGAL) project
    planned. 4,000 km pipeline from Nigeria to
    Algeria's export terminals on the Mediterranean.

6
Overview of the Nigerian Oil Gas industry
  • Plans to double electricity access, additional
    15,000 km transmission and 16 new power plants.
  • Running fast to equate gas revenue to oil revenue
  • Aggressively moving to stop gas flaring
  • Promote local content in gas to 100 in 2010 70
    onshore, 30 offshore
  • 13 of current gas is being produced and used
  • 12 is re-injected for oil enhancement total
    utilization 25
  • 75 flared

7
Upstream Crude Oil Fiscal Regime
The Nigerian Oil Extraction activities keep on
moving from one arrangement to the other while
the existing arrangement continues as parallel
running since 1958 to date. The current Position
is as below.
Condensate
8
Upstream Crude Oil Fiscal Regime
  • Oil Sector Upstream Regimes
  • Joint Venture
  • Cash-call challenges are moving the government
  • away from this arrangement
  • Sole Risk Operations
  • Local content directives of 60/40
  • funding, revenue tax sharing issues
  • Risk Service Contract
  • No increase in the numbers of RSCs
  • Production Sharing Contracts
  • The New order
  • Marginal Field operations
  • Hybrids

9
Current Crude Oil Gas Taxation Regimes
  • Presently, Nigeria operates the 3 PETROLEUM
    ARRANGEMENTS or
  • regimes that could be found anywhere in the
    world
  • Concessions (Licenses Lease JVs , Sole Risks)
  • (Countries practicing Nigeria, USA, Canada,
    Norway, UK, Russia, Brazil, Algeria, Saudi
    Arabia (for gas only), South Africa, Pakistan,
    Thailand and Australia)
  • Production Sharing Contracts
  • (Countries practicing Nigeria, Indonesia,
    Malaysia, India, Egypt, Gabon, Ivory Coast,
    Syria, Yemen and Trinidad and Tobago)
  • Risk Service Contracts
  • (Countries practicing Nigeria, Mexico, Iran,
    Iraq and Kuwait). Iraq and Kuwait practices
    Technical Services Agreement where IOCs only
    Consult for them while the operate 100.
  • All the regimes could result in the same
    Government Take() and Government Revenue
    (Undiscounted) and Discounted Revenue

10
Current Crude Oil Gas Taxation Regimes
  • Fiscal means all government take in cash or kind
    including
  • Bonuses (signature bonus, production bonus etc)
  • royalties,
  • corporate income taxes,
  • profit oil shares,
  • windfall profits taxes (Delayedlossloss)
  • property taxes,
  • export duties,
  • carried interest provisions,
  • and Contractors take in
  • Performance Fees / Bonus to Contractors
  • RSCs fees paid by government to the contractors
  • Profit oil share
  • Interest on intercompany/group funding

11
Current Crude Oil Gas Taxation Regimes
  • Factors driving government take
  • High Government Take (Max99)
  • development of low cost LIGHT OIL in already
    discovered fields
  • Low Government Take (Min25)
  • high risk exploration projects for small target
    fields
  • Offshore investments
  • Target
  • To maximise Govt revenue, Govt to maximise level
    of production
  • To increase level of Reserves. Increase in
    reserves does not mean increase in Production
    (Venezuela has 177 billion barrels of reserve but
    producing 2 billion barrels per annum in 2009
    from 72 billion barrels of reserve in 2004 with a
    production level of 3 billion)

12
Current Crude Oil Gas Taxation Regimes
  • Target (contd)
  • Government to encourage investor to ensure
    maximum production at lowest cost
  • Higher Government Take during high oil gas
    prices to avoid windfall profits
  • Increase in oil price from 2003 make governments
    to start adjusting their prices
  • In 2009 the prices started falling.
  • - Nigeria started reform in 2003 National Study
    Group / Working Group to Oil Gas Implementation
    Reform Committee leading to PIB

13
Current Crude Oil Gas Taxation Regimes
  • The government take is the share that the
    government
  • receives of the divisible income as government
    revenues.
  • Government take could be the same in the three
    arrangements
  • For instance, where Govt. take is 95 Government
    Revenue will be
  • USB USB
  • Gross Revenue 1b X 100 100
  • Less Capital Expenditure 3.5
  • Less Operating Expenditure 4.5
  • Total Cost 8
  • Divisible Income 92
  • Government Take 95 87.4
  • Contractors Take 4.6
  • 5 discounted Vakue of Govt revenue 52.2

14
Current Crude Oil Gas Taxation Regimes
  • Under Concession
  • USB USB
  • Gross Revenue 1b X 100 100
  • Less 46 Royalty 46
  • Less Costs 8
  • Total Cost
  • Taxable Income 46
  • Government Tax 90 41.4
  • Government Take 87.4
  • Contractors Take 4.6
  • 5 discounted Vakue of Govt revenue 52.2

15
Current Crude Oil Gas Taxation Regimes
  • Under PSC
  • USB USB
  • Gross Revenue 1b X 100 100
  • Less 46 Royalty oil 46
  • Less Costs 8
  • Total Cost
  • Taxable Income 46
  • Government Tax 90 41.4
  • Government Take 87.4
  • Contractors Take 4.6
  • 5 discounted Vakue of Govt revenue 52.2
  • Under RSC
  • USB USB
  • Gross Revenue 1b X 100 100
  • Less Costs 8
  • Contractors further paid 4.6pb 4.6

16
Current Crude Oil Gas Taxation Regimes
  • Presently, the UPSTREAM CRUDE OIL TAXATION is
    being governed by
  • The Petroleum Profits Tax Act , Cap P13, Laws of
    the Federation of Nigeria, 2004
  • Deep Offshore Inland Basin Production Sharing
    Contract Act Cap D3, LFN, 2004
  • Memorandum of understanding Agreements
  • Decided Cases
  • Side Letters

17
Current Crude Oil Gas Taxation Regimes
  • The UPSTREAM GAS TAXATION is being governed by a
    hybrid of
  • Petroleum Profits Tax Act
  • Companies Income Tax Act, Cap C21, LFN 2004 - Gas
    Utilization - Downstream Sector
  • NLNG Act 1990 1993.
  • The proposed PIB attempts to consolidate the
    taxation of the Upstream Crude Oil and upstream
    Gas into one Act.

18
Tax Reform in the Petroleum Industry
  • The Nigerian Tax Reform exercise started as far
    back as 2003 with the works of the Study Group
    led by Professor Dotun Phillips. There was also
    the Working Group led by Mr Seyi Bickestet that
    was set up to review the works of the Study Group
    with a view to fine-tuning the recommendations of
    the Study Group for implementation purposes.
  • The two groups identified the fact that many of
    the tax laws needed to be urgently reviewed of
    which Petroleum Profits Tax Act was one.

19
Tax Reform in the Petroleum Industry
  • The 9 Tax Bills sent to National Assembly were
  • 1. A Bill for an Act to establish the FIRS as an
    autonomous Service
  • 2. A Bill for an Act to amend the Companies
    Income Tax Act
  • 3. A Bill for an Act to amend the Petroleum
    Profit Tax Act
  • 4. A Bill for an Act to amend the Personal Income
    Tax Act.
  • 5. A Bill for an Act to amend the Value Added Tax
    Act
  • 6. A Bill for an Act to amend the Education Tax
    Act.
  • 7. A Bill for an Act to amend the Customs, Excise
    tariffs, etc. (Consolidation) Act.
  • 8. A Bill for an Act to amend the National Sugar
    Development Council Act.
  • 9. A Bill for an Act to amend the National
    Automotive Council Act.
  • As far back as 2005, we had it that the House of
    Representatives at its sitting of 10th August
    2005 has concluded deliberations on the general
    principle underlying the nine tax reform bills
    and referred same to its joint committees on
    Finance and Justice for further legislative
    action.
  • In April 2007, some of the Bills were passed into
    law which are 1, 2, 5, and 9. No 6 has been
    dropped while all others including the PPTA are
    outstanding.

20
Tax Reform in the Petroleum Industry
  • One would have thought that if a bill will be
    passed in order of importance, next to the
    Federal Inland Revenue Services should be the
    PPTA.
  • In 2007, there were two versions of the PPTA
    proposed amendment. The FIRS version and the NNPC
    version.
  • In 2008, the Oil Gas Implementation Committee
    came up with the recommendation of the PIB
    materially believed to be driven by the Nigerian
    National Petroleum Corporation (NNPC) and in
    December 2008, there was the 1st reading of the
    PIB Bill.
  • In 2009, significant work was done by both the
    Senate and the House of Representative including
    the 2nd reading that was done between March and
    May 2009 and the Public Hearing in July 2009.
  • In 2010, there were committee reviews. It is
    believed that the currently as at today September
    28 2010, the Committees are finalising their
    reports in preparation for the 3rd reading by
    both Houses.

21
Features of The Proposed National Gas Policy 2005
Highlights of the Gas Policy includeIntro. of
the Natural Gas (Fiscal Reform) Act Gas Tax
ActIntroduction of the Downstream Gas
ActUnbundling of NGC into GRC (regulatory),
NGTC (transmission), NGMC (marketing)Encourage
exports- WA Gas Pipeline project, NLNGFuture oil
field approval only if specific plans for
associated gas are includedPenalties for Gas
flaringElectricity Power Sector Reform Act
(EPSRA)Tax Issues next slide
22
Features of The Proposed National Gas Policy 2005
  • Highlights of the Tax Issues include
  • Gas Profits Tax (GPT) replaces PPT and CIT i.e
    would apply to both upstream and downstream
    sectors.
  • Separate income expenditure iro oil from gas
    and apply to tax separately level playing
    ground for non-oil players
  • VAT, import duties and Niger Delta Devt levy
    would continue to apply to Gas projects
  • Dividend payable from gas projects would be
    exempt from WHT
  • Royalty rate of 0

23
Petroleum Industry Bill (Act), 2010
Petroleum Industry Bill 2010 10 Parts , 495
Sections, 10 Schedules. Part I Fundamental
Objectives Part II - Institutions Part III -
Upstream Petroleum Incorporated Joint Ventures
Part IV - Downstream Licensing Part V
- Downstream Products Part VI - Indigenous
Oil Companies and Nigerian Content Part VII-
Health, Safety and Environmental
Responsibilities over the Environment PART
VIII - FISCAL PROVISIONS (Section 414
477) Part IX Repeals, Transitional and Savings
Provisions Part X- Interpretation and
Citation The bone of contention has been Part
VIII. Meanwhile the problem of not agreeing and
passing the bill is a loss of Government Take
and huge uncertainty on the side of the IOCs.
24
Petroleum Industry Bill (Act), 2010
  • Also in 2010, the Inter Government Agency Team,
    IAT comprising of key ministries have come up
    with a draft of how PIB should look like.
  • As it is now, it still has to pass through the
    concurrence of the Houses, Presidential approval
    and Assent. In May 2010, the Honourable Minister
    for Petroleum Resources was optimistic that that
    the Bill would be passed very shortly.
  • There is a very huge uncertainty as to whether
    the bill will be passed before the end of 2010 in
    view of the coming election in April 2011.
  • There is also a huge uncertainty as to what is
    going to be the content of the Act when passed
    into law.
  • In summary, with respect to the timing of the
    passage of the PIB, just as it has been from the
    inception to date, the UNCERTAINTY continues !!!

25
Implications of Delayed Passing of the Bill
  • Between 2003 and 2009 there was increase in crude
    oil price and Governments with crude oil
    resources all over the world carried out reform
    to benefit from the windfall. It is by way of
    adjustment to the Government Take in the form of
    FISCAL ADJUDSTMENT.
  • Currently under the JV, Nigeria takes averagely
    86 94 which is estimated to be increasing to
    increasing to 96 under the proposed PIB
  • Currently Nigeria takes averagely 61 moving to
    82. Leaving IOCs with about 18 from 39.

26
PIB Tax Provisions Opportunities Challenges
of Implementation
  • Increased royalty with change in base from water
    depth to production value. Rate up to 25.
  • Dual tax filing for Upstream Oil operations i.e.
    NHT and CIT
  • Introduction of Dividend Withholding Tax (10)
  • Introduction of minimum tax at a percentage of
    gross revenue capital allowance restriction
    eliminated

27
PIB Tax Provisions Opportunities Challenges
of Implementation
  • Stricter rules governing tax deductibility of
    costs
  • Basis for taxes and royalties on production
    instead of actual sales
  • Separate tax regime for the midstream sector and
    introduction of the measurement point to
    demarcate the upstream from the midstream

28
PIB Tax Provisions Opportunities Challenges
of Implementation
  • Commencement date
  • Setting the right commencement date
  • Eliminating complications
  • January 1 of any year as appropriate date
  • Negotiated Terms (Section 4)
  • Opportunity to come to a common understanding
    and agreement that whatever TERMS are agreed
    between Applicants and the Minister of Petroleum
    Resources will be binding on the Federal Inland
    Revenue Service (FIRS).

29
PIB Tax Provisions Opportunities Challenges
of Implementation
  • A Friendly Taxation policy ( Section 6)
  • The Federal Government shall, to the extent
    possible ..promote .a taxation policy that
    encourages fuel efficiency by producers and
    consumers (Economically viable? Certainty?)
  • Minister of Petroleum Resources Overall Function
    (Section 9, 10 11)
  • The Minister in charge of petroleum resources
    shall be responsible for the co-ordination of the
    activities of the petroleum industry and shall
    have overall supervisory functions over petroleum
    operations and all the Institution of the
    Industry.

30
PIB Tax Provisions Opportunities Challenges
  • The Minister shall represent the Federal
    Government in all transactions between Government
    and any other persons in respect of any matter
    contemplated by this Act
  • The Minister may by regulations prescribe all
    matters which under this Act are required and
    necessary to give effect to this Act
  • Is the FIRS having the same understanding?
  • 2 Earmarked Levy (Section 28)
  • .Shall be paid by every company engaged in
    petroleum operations.

31
PIB Tax Provisions Opportunities Challenges
  • The exact percentage of fiscalised crude or
    fiscalised natural gas, as the case may be, shall
    be as contained in the guideline that shall be
    issued by the Minister on the advise by the
    Directorate, three months before the end of the
    financial year preceding the year in which the
    guideline will be applicable and shall be an
    amount not greater than 2....
  • What happens if no guideline is issued at the
    end of the year that the guideline relates?
  • Can Uncertain Tax Provision be (UTP) reduced?

32
PIB Tax Provisions Opportunities Challenges
  • Tax Deductibility of the 2 Earmarked Levy
    (Section 34)
  • Where contribution to the fund of the
    Directorate are made by a person subject to tax
    under the provision of any law in force in
    Nigeria, all such contribution shall be tax
    deductible
  • Where provisions are made and guideline was not
    issued, are such provisions tax deductible?

33
PIB Tax Provisions Opportunities Challenges
  • Tax Audit / Revenue Assurance (Section 59)
  • Office of Auditor General of the Federation was
    to audit the Inspectorate. Should the Office of
    Auditor General of the Federation audit the books
    of private companies for compliance ?
  • Costs Approval (Section 114)
  • The National Petroleum Assets Management Agency
    (NPAMA) shall be in charge of monitoring and
    approving costs in the upstream petroleum
    industry of Nigeria with the objective of
    maximizing the total revenue accruing to the
    government

34
PIB Tax Provisions Opportunities Challenges
  • Costs Approval (Section 114) (Contd.)
  • If a cost is not cost recoverable, does it have
    any bearing with tax deductibility? (section 115
    (g) requires the agency to liaise with the FIRS
    for cost deductibility)
  • If a cost is recovered, will charging the amount
    as tax deductible amount to a double claim?

35
PIB Tax Provisions Opportunities Challenges
  • Evidencing Tax Payment (Tax Receipt) (Section
    115)
  • The function of the agency shall be
  • (f) to receive and dispose of petroleum accruing
    to the Federal Government which is produced under
    production sharing contract, consisting of TAX
    and Royalty OIL but not profit oil.
  • Will the FIRS issue Official Receipt for
    uncollected taxes?

36
PIB Tax Provisions Opportunities Challenges
  • Transfer of Assets from NOC/IOCs to IJVC /
    incorporated PSC Company (Section 137/ 246 / 256)
  • Can the transfer be deemed to be a statutory or
    compulsory transfer with no transaction taxes
  • CGT,
  • VAT,
  • Stamp duties
  • WHT ?
  • Is there a need for a special application?

37
PIB Tax Provisions Opportunities Challenges
  • Definition Issues (Section 414)
  • Contract Area means the contract area as
    defined in the PSC
  • Can two or more blocks be a contract area for
    tax deductibility purposes ?
  • Can the Tax Treatment of condensate not Spiked?
    (if any) (Section 419 (1a) be agreed) ?

38
PIB Tax Provisions Opportunities Challenges
  • Application of Accounting Period (Section 420)
  • With respect to the definition of an accounting
    period, what would be tax treatment of
    pre-production operating expenses?
  • Allowable Deductions (Section 420)
  • To be
  • Benchmarked (price set by the authority S494)
  • Verified
  • Approved
  • 100 Cost incurred in Nigeria allowable / 80 of
    costs incurred outside Nigeria

39
PIB Tax Provisions Opportunities Challenges
  • Allowable Deductions (Section 420)
  • No mention was made of Interest allowable
    (Section 421 (2) disallows intercompany interest
    chargeable).
  • Pension - Allowable Deductions (Section 420 j )
  • Any contribution to a pension, provident or
    other society, scheme or fund which may .be
    approved by the Board.
  • What makes of Pencom Approval?

40
PIB Tax Provisions Opportunities Challenges
  • Regime Clarification and Applicable Tax Rates
    (Section 429 / 430)
  • 50 - NHT (Onshore shallow water)
  • 30 - Offshore Plus
  • 30 CIT
  • Earlier proposal
  • 50 - PSC Upstream Crude Oil
  • 60 - Indigenous company (lt50k b)
  • 45 - JV Upstream Gas
  • 35 - PSC Upstream Gas
  • - If an indigenous co crosses to over 50,000
    barrels per day, what rate is applicable?

41
PIB Tax Provisions Opportunities Challenges
  • - If a new co farm in into assets existing from
    more that 5 years, what rate is applicable?
  • Investment Tax Credit or Petroleum Investment
    Allowance (Section 431)
  • The title and the body should align to eliminate
    ambiguities.

42
Some recent allegations of Petroleum Profits Tax
Evasion / Case study
  • Case study 1 (Thisday News 21 May 2008)
  • YarAdua Orders Shell, ExxonMobil to Refund
    N236bn
  • President Umaru Musa YarAdua has ordered the
    Nigerian National Petroleum Corporation (NNPC) to
    immediately recover outstanding payments of 1.91
    billion (N236 billion) due to the Federal
    Government from Shell and ExxonMobil on the
    Production Sharing Contracts (PSCs) for the Bonga
    and Erha oil fields.President YarAdua
    directed as follows That the total sum of 1.496
    billion accruable to NNPC based on the proper
    application of the PSCs capital allowance should
    be recovered. This sum is made up of 850 million
    from Bonga and 646.3 million from ErhaThat
    the sum of 414.6 million accruable to NNPC and
    to government from Bonga gas sales and as tax
    revenue from the gas sales should be recovered
    and
  • That all future government gas sales agreements
    should account for Natural Gas Liquids (NGLs) to
    ensure that government derives maximum economic
    benefits from them and that this position be
    adopted in the renegotiation of all existing PSC
    agreements which are due for renegotiation, he
    said.
  • Question Ambiguity leading to Tax Disagreement
    or outright case of Tax Evasion?

43
Some recent allegations of Petroleum Profits Tax
Evasion / Case study
  • Case study 2 (Thisday News 15 November 2006)
  • The 500 Billion Question
  • Using the final tax returns submitted to the
    Federal Inland Revenue Service (FIRS) by Shell,
    Mobil, Chevron Nigeria, Nigeria Agip Oil Company
    (NAOC), Texaco and Elf, the Okogu-led unit
    started by conducting a study on the margin of
    profit allowed to oil companies under the
    Memorandum of Understanding (MoU) based on the
    existing fiscal regime, a study which revealed
    very clearly that Nigeria was being shortchanged
    by the oil majors. With the report, Okonjo-Iweala
    thought that on her own, working with FIRS, she
    could arm-twist the oil companies to pay back the
    340 million shortfall by the calculations done.
    .."Part of the incentive package granted to
    oil companies under the Memorandum of
    Understanding (MOU) in the Joint Venture
    agreements was a guaranteed margin of at least
    2.50 per barrel irrespective of the oil price.
    In addition, the companies are allowed an extra
    margin based on a formula that escalates the base
    margin when the price lies between 19 and 30
    per barrel, which works out at 4.147 when the
    oil price reaches 30. If the price stays above
    this level for 45 consecutive days, the MOU
    states that the Oil Minister would advise the oil
    companies on any change in applicable margin.
  • After reading this memo, the president was said
    to have exclaimed "Are you sure of your
    facts?"Okonjo-Iweala answered in the
    affirmative. There and then, Obasanjo requested
    that a letter be drafted for him to the oil
    majors. The next day, he signed the letter as the
    de facto oil minister and within weeks, 340
    million was returned to the Nigerian treasury by
    the oil companies. Just like that!

44
Case studies issues identified
  • Case study 1 - YarAdua Orders Shell, ExxonMobil
    to Refund N236bn based on the proper
    application of the PSCs capital allowance and
    the gas sales That all future government gas
    sales agreements should account for Natural Gas
    Liquids (NGLs)...
  • Questions 1) Was it a tax evasion? Tax
    avoidance? Or Tax Uncertainty and Controversy?
  • 2) Was there a clear understanding?
  • 3) Was there a genuine efforts to seek
    clarifications by the NNPC the contractors
  • 4) Who should be blamed for the gaps in the laws
    and its poor admin? Govt or Operators?
  • 5) Should the only one issue identified be the
    one to address?

45
Case studies issues identified
  • Case study 2
  • The 500 Billion Question - a study on the margin
    of profit under the Memorandum of Understanding
    (MoU) based on the existing fiscal regime, a
    study which revealed very clearly that Nigeria
    was being shortchanged by the oil majors. 340
    million was returned to the Nigerian treasury by
    the oil companies. Just like that!
  • Questions 1) Was it a tax evasion? Tax
    avoidance? Or Tax Uncertainty and Controversy?
  • 2) Was there a clear understanding?
  • 3) Was there a genuine efforts to seek
    clarifications by the NNPC the contractors
  • 4) Who should be blamed for the gaps in the laws
    and its poor admin? Govt or Operators?
  • 5) Should the only one issue identified be the
    one to address?

46
Conclusion
  • It will be a great opportunity to use the
    Petroleum Industry Bill, 2010 to address all the
    issues identified.
  • If not addressed, those issues would obviously
    from part of the future challenges of
    implementing the Bill when passed into law.

Thank you.
47
  • It Can only be better !

Thank you.
48
References
  • Petroleum Profits Tax Act , Cap 13 LFN 2004
  • Deep Offshore Inland Basin Production Sharing
    Contract Act Cap D3, LFN, 2004
  • Companies Income Tax Act, Cap C21 LFN 2004
  • The Petroleum Industry Bill 2010
  • Petroleum Accounting Taxation in Nigeria, R U
    Uche, PhD, FCA in collaboration with K A Adebiyi,
    FCA (2002)
  • Overview of Country Oil Gas Tax Practices
    Ernst Young (2008)
  • Thisday News 21 May 2008)
  • Thisday News 15 November 2006)
  • Nigerian Tax Reform Manual, 2003
  • Nigeria Oil Gas Monthly Magazine .
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