Serviceeftersyn af vilkårene for kulbrinteudvinding ... - Skatteministeriet

Fiscal Comparison/Exploration Attractiveness
Concessions granted before 2004 are liable to a 70 % Hydrocarbon Tax calculated after deduction of an uplift of 25 % in
10 years. The royalty is 5 %. Concessions granted after 2004 and the Sole Concession from 1962 is liable to a 52 %
Hydrocarbon Tax after deduction of an uplift of 6 % in 5 years. The royalty can be deducted in the Hydrocarbon Tax and
is abolished from July 8, 2012.
Norway fiscal terms overview
Norway has a concession fiscal regime where royalty has been abolished for all fields. Corporate income tax (28%) and
an additional profits tax (Special Tax, at 50%) are both payable and not deductible against each other, hence the total
marginal tax rate payable is 78%. Some minor Carbon Dioxide (CO2) and Nitrogen Oxide (NOx) levies are payable on
gas flared, gas or oil/condensate used for power generation and nitrous oxide emissions.
Introduction of exploration incentives in 2005 has encouraged new entrants, but no further changes in the fiscal system
are currently planned or known about.
The Netherlands fiscal terms overview
The Netherlands has a concession fiscal regime where the applicable taxes, and the level of State participation, vary with
the location and vintage of the licence. The state participates through Energie Beheer Nederland (EBN), normally with a
40% share (EBN participation is 50% for licences issued under 1976 Royal Decree) and including the exploration phase,
through a so-called ‘cost company’ structure, similar to a joint venture.
Royalty has been abolished for offshore licences, and for onshore licences varies with production rate and the level of
state participation. Corporate income tax is payable (at a rate of 25.5%), but is deductible against an additional profits
tax (known as Production Profit Tax (PPT) or State Profit Share (SPS)) (at a rate of 50%), and hence the total tax
payable is, effectively, the PPT rate, of 50%.
In 2010, the government introduced an extra 25% investment deduction on investments from PPT (not CIT) for selected
marginal fields.
UK fiscal terms overview
All upstream operations in the UK are governed by concessions. Government take on new field developments currently
comprises of corporation tax (CT) and a supplementary charge (SCT). CT is levied at a rate of 30% and SCT at 32%, to
give a marginal tax rate of 62%.
Fields with development approval prior to 16 March 1993 are liable to Petroleum Revenue Tax (PRT) at a rate of 50%, in
addition to CT and SCT. The marginal tax rate on fields subject to PRT, as well as CT and SCT, is 81%.
2.3 Comparison of average, marginal and model field tax rates
Three types of tax rate comparison are provided in this report:
• Average Tax Rates
• Marginal Tax Rates
• The tax rates which apply to a number of model fields using different oil and gas price assumptions
The average tax rates for each country for the period 2007 to 2011 are shown in the table below. For Denmark two
averages are provided: Denmark old fiscal regime (which applies to Syd Arne, Siri Cecile, Nini and 50% of Lulita);
Denmark new fiscal regime (which applies to the rest of the fields):
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