内容

目次

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