Title:
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Petroleum taxation : a critical evaluation with special application to the UK continental shelf
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This thesis provides a framework of economic analysis which both Governments and
the petroleum industry can draw upon in their negotiation of fiscal terms that offer a fair
and just basis of wealth allocation. Its principal objectives are to critically evaluate the
petroleum fiscal regime in the UK North Sea since 1975, and identify a fiscal regime
that is acceptable to Government and oil industry alike.
Government and oil companies are the key decision-makers in the upstream sector of
petroleum industry. However, their individual focus is one of competing rather than
complementary objectives. Governments of oil producing countries face important
challenges when designing a tax system that meets the two fundamental objectives of
ensuring a fair share of revenues for themselves whilst simultaneously providing
sufficient incentives to encourage investment. Besides, petroleum resource has special
features that can impose further difficulties in the design and implementation of an
appropriate tax system aimed at achieving a balance between both Government and
industry interests'.
Over the years, achieving this balance has given rise to significant controversy in the
UK. The structure of the current fiscal regime was formally legislated through the Oil
Taxation Act of 1975. However, the regime has been frequently reviewed and amended.
Its current structure is significantly different from its original version. Th~ various
amendments to the regime have led researchers and specialists to either criticising or
supporting Government actions.This thesis conducts an in depth analysis on the principal fiscal packages that have
applied to the UKCS and analyses their effect on the balance between the Government
and oil companies' objectives. The research is carried out in the light of an essential and
timely feature, the current maturity of the UK oil province. The thesis demonstrates
that, in practice, it is very difficult to develop an ideal fiscal package. Several
complications are associated with petroleum taxation, resulting mainly from the
difficulty in determining a suitable tax base as well as the inevitable compromises to the
criteria that are required to categorise an optimal tax. Consequently, it is not surprising
to find that none of the tax instruments proposed in previous studies or those applied in
the UK represents an optimal tax.
The UK petroleum fiscal regime suffered from several limitations. However, currently,
the UK fiscal regime is one of the most attractive regimes in the world, from an
investor's standpoint. Government take is lower than the pre-1993 fiscal structures, but
any future concerns about UKCS taxation must take into account the current maturity of
the petroleum reserve base. A high level of Government take is not recommended in
cases of high-risk exploration, high-cost development, or for those provinces with
modest petroleum potential, as is the case in the UK North Sea.
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