Australia: Consultation on petroleum resource rent tax (PRRT) tolling arrangement and anti-avoidance rules amendments

Consultation on the draft documents will close on 9 February 2024.

Consultation on the draft documents will close on 9 February 2024.

The Australian Treasury has released exposure draft documents proposing to update the petroleum resource rent tax (PRRT) and amend its anti-avoidance rules and clarify certain tax treatment definitions.

The first draft, the “Petroleum Resource Rent Tax Assessment Regulations 2023” [PDF 452 KB] (2023 Regulations), would reform the methodology used in the PRRT Assessment Regulation 2015 to calculate the price of sales gas processed into liquefied natural gas, including the advanced pricing arrangement and comparable uncontrolled price rules, and expressly include tolling arrangements in the regulations.

The second set of drafts includes the “Treasury Laws Amendment (Measures for Future Bills) Bill 2023: PRRT Anti-Avoidance Rules” [PDF 877 KB] and the “Treasury Laws Amendment (Measures for Consultation) Bill 2023: Capital Allowances for Mining, Quarrying or Prospecting Rights and Clarifying the Meaning of Exploration for Petroleum” [PDF 850 KB].

  • The PRRT anti-avoidance rules draft seeks to align the anti-avoidance provisions in the PRRT Assessment Act 1987 (PRRTAA) with the general anti-avoidance rules in the Income Tax Assessment Act 1936.
  • The capital allowances draft bill clarifies the tax treatment of “exploration” in the PRRTAA and “mining, quarrying and prospecting rights” (MQPRs) in the Income Tax Assessment Act 1997 so that PRRT and income tax legislation operate as intended.

Consultation on the draft documents will close on 9 February 2024. The federal government plans to consult on draft legislation implementing the remaining elements of its response to the gas transfer pricing review in early 2024. 



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