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Africa: EY’s oil and gas<br />

tax capabilities


2 Africa: EY’s oil and gas tax capabilities


Contents<br />

It’s time for Africa .....................................................................2<br />

Natural gas in Africa: the frontiers of the Golden Age ..........................4<br />

Our global organization .............................................................5<br />

Our dedication to oil and gas .....................................................6<br />

We understand your business ....................................................7<br />

Our presence in Africa ............................................................. 10<br />

EY’s oil and gas tax services in Africa ....................................... 11<br />

EY oil and gas tax contacts in Africa .........................................12<br />

Africa: EY’s oil and gas tax capabilities<br />

1


It’s time for Africa<br />

Africa is on an upward curve. According to the World Bank,<br />

Africa could be on the brink of an economic takeoff, much like<br />

China was 30 years ago and India 20 years ago. 1 This growth is<br />

underpinned by a longer-term process of economic and regulatory<br />

reform that has occurred across much of the continent since the<br />

end of the Cold War, a period during which inflation has been<br />

brought under control, foreign debt and budget deficits were<br />

reduced, state-owned enterprises privatized, regulatory and legal<br />

systems strengthened, and many African economies opened up<br />

to international trade and investment. Political stability in African<br />

countries is leading to a legal and tax environment that becomes<br />

more certain, but also more challenging for existing operations.<br />

Such challenges arise as governments react more quickly to adapt<br />

their tax environment to changing economic conditions.<br />

Most African economies proved resilient through the global<br />

financial crisis, with the sub-Saharan region, for example,<br />

rebounding very strongly from a slight dip in 2009 to grow,<br />

according to International Monetary Fund (IMF) estimates, by<br />

more than 6% in 2012. The region is expected to grow by more<br />

than 7% in 2013, and by an average of almost 8% per year over<br />

the 2014–2018 period. 2<br />

African economic growth vs the BRICs<br />

As an aggregate market, Africa is large: according to the IMF,<br />

in purchasing power parity terms, its GDP share of the world total<br />

was estimated at about 4% in 2012, which is almost equal to India<br />

and greater than Russia and Brazil. Business leaders are planning<br />

new developments and expanding existing ones, demonstrating<br />

why Africa’s share of new global foreign direct investment<br />

(FDI) projects has improved recently. Looking forward, capital<br />

investments are forecast to grow to US$150b in 2015 and create<br />

350,000 jobs per annum. 3 Although Africa currently attracts more<br />

than 5% of global FDI projects, we believe this does not reflect<br />

the increasing attractiveness of the African growth story. Africa<br />

is unusual in this respect. Although Africa’s proportion of global<br />

FDI has grown to some extent over the last decade, it does not<br />

accurately reflect a region that has one of the fastest economic<br />

growth rates and highest returns on investment in the world. 4<br />

Africa’s share in global new FDI projects<br />

20%<br />

15%<br />

10%<br />

5%<br />

0%<br />

-5%<br />

1,000<br />

900<br />

800<br />

700<br />

600<br />

500<br />

400<br />

300<br />

200<br />

100<br />

0<br />

5.2%<br />

5.4%<br />

5.6%<br />

3.5%<br />

3.2%<br />

899 867<br />

764<br />

339<br />

421<br />

2003 2007 2008 2011 2012<br />

6.0%<br />

5.0%<br />

4.0%<br />

3.0%<br />

2.0%<br />

1.0%<br />

0.0%<br />

Africa’s Total<br />

Africa’s % Share of Global Total (Rhs)<br />

-10%<br />

2007<br />

2008<br />

2009<br />

2010<br />

2011<br />

2012<br />

2013<br />

2014<br />

2015<br />

2016<br />

2017<br />

2018<br />

Source: FDI Markets; EY Analysis<br />

Brazil<br />

India<br />

Sub-Saharan Africa<br />

China<br />

Russia<br />

Source: International Monetary Fund (IMF), World Economic Database,<br />

April 2013<br />

1. “Africa’s Future and the World Bank’s Support to It,” The World Bank, March 2011.<br />

2. International Monetary Fund, Global Economic Database, April 2013.<br />

3. Oxford Economics research conducted on behalf of EY.<br />

4. The assertion of high returns is supported by a number of studies, including: Foreign<br />

Direct Investments in Africa: Performance and Potential, UNCTAD, 1999; Collier and<br />

Warnholz, “Now’s the Time to Invest in Africa,” Harvard Business Review, February<br />

2009; Warnholz, “Is Investment in Africa low despite high profits?” Working Paper,<br />

Centre for Study of African Economics, 2008; Lions on the move: The progress and<br />

potential of African economies, McKinsey Global Institute, June 2010; The African<br />

Challengers: Global competitors emerge from the overlooked continent, Boston<br />

Consulting Group, 2010.<br />

2 Africa: EY’s oil and gas tax capabilities


Political stability in African countries is leading to a legal and tax environment that becomes more<br />

certain, but also more challenging for existing operations. Challenges come from the increasing<br />

reaction speed of governments to adapt their tax environment to changing economic conditions.<br />

Resources generally, and oil and gas specifically, have played<br />

an important role in the continent’s growth. Nineteen African<br />

countries are significant producers of oil and/or gas, and the<br />

revenues from higher prices and the investments that new<br />

discoveries are attracting have made a key contribution to growth.<br />

At the end of 2012, African oil and gas reserves were estimated to<br />

be more than 215 billion barrels of oil equivalent (boe). 5 While the<br />

majority of proved reserves and production remains concentrated<br />

in six countries — Nigeria, Libya, Algeria, Angola (oil), South Sudan<br />

(oil) and Egypt (gas) — there have been significant new discoveries<br />

in Ghana, Tanzania, Mozambique, Kenya and Uganda, with strong<br />

prospects also seen in Sierra Leone and Mali. Most of these new<br />

discoveries are not yet counted as proved reserves. Nigeria,<br />

Algeria and Libya currently dominate reserves, and the three<br />

countries collectively account for more than 75% of the region’s<br />

total proved reserves.<br />

African proved reserves of oil and gas (end-2012)<br />

Nigeria<br />

31%<br />

S Sudan<br />

2%<br />

Other<br />

8%<br />

Libya<br />

26%<br />

Algeria<br />

18%<br />

Angola<br />

7%<br />

Egypt<br />

8%<br />

Source: BP Statistical Review of World Energy, BP plc, June 2013<br />

So it is not surprising that investors are optimistic about the<br />

potential for growth in the African oil and gas sector. While Africa<br />

as elsewhere, has risks, the rewards are commensurately high.<br />

In addition, oil and gas tax terms in certain African countries are<br />

considered as competitive on a worldwide basis. As the oil and gas<br />

tax regime is new for many African countries, EY tax professionals<br />

cooperate with tax authorities and governments, providing<br />

experience and advice on developing legislation.<br />

As the oil and gas tax regime is new for<br />

many African countries, EY tax professionals<br />

cooperate with tax authorities and<br />

governments, providing experience and<br />

advice on developing legislation.<br />

5. “BP Statistical Review of World Energy,” BP plc, June 2013<br />

Africa: EY’s oil and gas tax capabilities<br />

3


Natural gas in Africa: the frontiers<br />

of the Golden Age<br />

The world may be poised at the beginning of the Golden Age<br />

of Gas, with natural gas being the only fossil fuel whose share<br />

of the global energy mix is expected to grow. That expected<br />

growth is to be driven by developments on both the demand<br />

side — such as energy demand growth in China, the displacement<br />

of coal-fired and nuclear power, and the displacement of some oil<br />

products in transportation — and on the supply side, such as the<br />

unconventional gas boom and the growing role of liquefied natural<br />

gas (LNG). Africa is currently a small but growing part of the global<br />

gas picture, and its prospects are even brighter still. With relatively<br />

open access and generally attractive leasing terms, Africa’s oil<br />

and natural gas resources have long attracted a broad spectrum<br />

of investors — from the large integrated, international majors to<br />

the large and small independent exploration and production (E&P)<br />

companies, as well as national oil companies (NOCs) from outside<br />

the region. North Africa has historically led the continent’s gas<br />

sector, but recent growth has come from the huge associated gas<br />

developments that have accompanied the West African offshore oil<br />

boom. But with the huge recent discoveries in offshore East Africa<br />

(in particular, Mozambique and Tanzania), the future of African gas<br />

is expected to shift eastward.<br />

Development of Africa’s unconventional gas resources — largely<br />

in North Africa and South Africa — could also substantially add<br />

to the potential new supply. Natural gas development holds<br />

tremendous opportunity for Africa, and it can be a strong “prime<br />

mover” for broader economic and social development. But those<br />

opportunities come with risks and challenges — some that are<br />

beyond the control of local/regional industry and government<br />

and others that, while daunting, can be managed but will need<br />

resolute and dedicated attention. Most importantly though, the<br />

opportunities for Africa presented by the Golden Age of Gas are<br />

enormous, and the challenges and risks can be addressed and<br />

mitigated, if not fully overcome.<br />

A decade ago, the world was estimated to have only 50 to 60<br />

years’ worth of gas remaining; with the new unconventional<br />

supply, the estimated resource life has risen to more than 200<br />

years. 6 The world’s first large-scale LNG liquefaction facility<br />

opened in Algeria in 1964, and by early 2012, 19 countries had<br />

liquefaction capacity and/or were exporting LNG. Global trade in<br />

LNG has grown from approximately 3 billion cubic meters (bcm)<br />

in 1970 to more than 330 bcm in 2011. In early 2012, LNG import<br />

capacity (as in, import terminals/regasification plants) existed in<br />

25 countries. Global LNG liquefaction capacity, as of early 2012,<br />

is approximately 300 metric tons per year (MT/yr). 7 With the<br />

planned and proposed/possible additions to liquefaction capacity,<br />

global capacity could reach 750 MT/yr by 2020. 8 Natural resource<br />

development, particularly oil and natural gas, is a “foundational”<br />

element of economic growth and development. In developing<br />

countries, it typically accounts for a significant part of the state’s<br />

revenues, and more importantly it represents a “prime mover” for<br />

employment, infrastructure development and the improvement of<br />

the broader social well-being. 9<br />

African natural gas production and disposition<br />

(demand + net exports = total production)<br />

Billion cubic metres (bcm)<br />

450<br />

400<br />

350<br />

300<br />

250<br />

200<br />

150<br />

100<br />

50<br />

0<br />

2010 2015f 2020f 2025f 2030f 2035f<br />

Demand<br />

Net exports<br />

Source: EY calculations from International Energy Agency data in the<br />

World Energy Outlook 2012<br />

6. “Special Report: An Unconventional Bonanza,” The Economist, 14 July 2012<br />

7. Liquefaction capacity is typically expressed in metric tons per year (MT/yr), whereas<br />

gas production, consumption and trade are typically measured in terms of cubic<br />

meters or cubic feet. One MT of LNG is roughly the equivalent of 1.36 billion cubic<br />

meters (bcm) of natural gas<br />

8. “Global LNG,” J.P. Morgan Cazenove — Global Equity Research, 13 January 2012<br />

9. “McKinsey Quarterly: Africa’s path to growth,” McKinsey & Company, June 2010<br />

4 Africa: EY’s oil and gas tax capabilities


Our global organization<br />

EY is one of the world’s leading professional services<br />

organizations, committed to doing its part in building a better<br />

working world with extensive knowledge and hands-on industry<br />

experience.<br />

In a better working world trust increases, capital flows<br />

smoothly and investors make informed decisions. A better<br />

working world also develops talent in all its forms and<br />

encourages collaboration. The insights and quality services<br />

that EY delivers help build trust and confidence in the world’s<br />

capital markets and economies.<br />

Our professionals think globally and act locally on our client’s<br />

behalf. Our firm has a strong account management philosophy,<br />

supported by leading-edge knowledge management and<br />

seamless technology. We accomplish this level of service<br />

through highly effective internal communication.<br />

For many years, our firm has been at the forefront of providing<br />

leading advice to the oil and gas industry worldwide. EY ranks<br />

first among all firms in providing external audit services to<br />

public companies in the Fortune 1000. Our leadership and<br />

presence across the country and around the world provide our<br />

clients with readily accessible, highly experienced professionals<br />

anywhere they conduct business — today and tomorrow.<br />

Fortune 1000<br />

Big Four audit<br />

market share*<br />

Other<br />

2%<br />

KPMG<br />

19%<br />

EY<br />

30%<br />

PwC<br />

26%<br />

Deloitte<br />

23%<br />

*By number of companies audited as of May 2013<br />

Africa: EY’s oil and gas tax capabilities<br />

5


Our dedication to oil and gas<br />

EY’s Global Oil & Gas practice consists of a network of more<br />

than 9,600 professionals with extensive experience working in<br />

the oil and gas industry. Our professionals serve a wide range of<br />

companies — independent exploration and production companies,<br />

oilfield services companies, independent refiners, major integrated<br />

corporations and national oil companies.<br />

Our Global Oil & Gas Centers, like the professionals in our<br />

Global Oil & Gas practice, are strategically located in areas that<br />

allow us to best serve the needs of the oil and gas industry. In<br />

addition to our Houston, London, Moscow and Bahrain Centers,<br />

we have Satellite Centers in Aberdeen, Beijing, Brisbane, Calgary,<br />

Cape Town, Johannesburg, Lagos, Perth, Rio de Janeiro,<br />

Singapore and Stavanger.<br />

Our experienced and dedicated Global Oil & Gas Center resources:<br />

• Anticipate market trends and identify the services that companies<br />

in the oil and gas industry need<br />

• Execute the mobility of our global resources so that we provide<br />

the right people in the right places at the right time to serve<br />

our clients<br />

• Develop and deliver oil and gas specific training to our<br />

professionals to provide the knowledge necessary to deliver<br />

high-quality services to our clients<br />

• Develop points of view on relevant industry issues so that our<br />

clients stay informed about key developments and trends<br />

Our deep industry focus helps EY make a difference. It allows us<br />

to help companies in the oil and gas industry meet their goals and<br />

compete more effectively.<br />

Calgary<br />

Aberdeen<br />

Stavanger<br />

London<br />

Europe, Middle East, India and Africa<br />

4,800 professionals<br />

Moscow<br />

Beijing<br />

Houston<br />

Bahrain<br />

Americas<br />

3,300 professionals<br />

Lagos<br />

Asia-Pacific and Japan<br />

1,500 professionals<br />

Singapore<br />

Rio de Janeiro<br />

Johannesburg<br />

Perth<br />

Brisbane<br />

Cape Town<br />

EY has established a global network of<br />

more than 9,600 professionals supported<br />

by 15 Global Oil & Gas Centers.<br />

6 Africa: EY’s oil and gas tax capabilities


We understand your business<br />

The oil and gas industry is going through a period of fundamental<br />

change. The challenges of meeting growing global demand for<br />

energy against the backdrop of naturally declining production and<br />

reserves from existing fields are significant. In order to meet these<br />

challenges, the industry is moving into new areas with the growth of<br />

unconventional resources as a cost-effective, viable resource: ultra<br />

deepwater and the Arctic. With the International Energy Agency<br />

(IEA) forecasting approximately $20 trillion needing to be spent<br />

to meet future demand for oil and gas between now and 2035,<br />

the issues oil and gas companies are facing span the technical,<br />

commercial, financial and HSE aspects of their business. 10<br />

We have indentified below a number of key industry issues and<br />

highlighted some of the ways in which EY is assisting companies in<br />

meeting those challenges.<br />

Industry issues<br />

How is EY assisting?<br />

Regulatory compliance<br />

Recent years have seen both an increase in regulation and an<br />

increased focus on regulatory compliance. Companies have<br />

increased their efforts to ensure compliance with existing and new<br />

regulations, such as Sarbanes-Oxley (SOX) and the Foreign Corrupt<br />

Practices Act. Many companies also face increased environmental<br />

reporting requirements and managing the transition to International<br />

Financial Reporting Standards in certain geographies. The pace<br />

of change in this area is likely to accelerate with Dodd-Frank, the<br />

UK Bribery Act, potential new deepwater drilling regulations, and<br />

increasingly stringent environmental regulation and reporting all<br />

set to add to the workload of the compliance functions, finance<br />

departments and the broader organization.<br />

Counterparty risk<br />

Historically, oil and gas companies have entered into joint ventures<br />

on large projects to share capital, technology, expertise and risk.<br />

The attention on joint ventures and contracting partners has<br />

been put into focus by recent events and can expose companies<br />

to considerable financial and reputational risk. There needs to be<br />

absolute clarity within these contracts regarding responsibilities,<br />

decision-making and potential legal liabilities. In addition to this<br />

contractual clarity, there will be an increased emphasis on venture<br />

partner and contractor financial strength and their ability to<br />

withstand the potential financial pressures that result from a major<br />

incident.<br />

• Completing statutory audits<br />

• Completing sustainability audit assurance<br />

• Completing compliance risk assessments<br />

• Identifying and implementing improvements to the controls<br />

framework<br />

• Identifying and implementing controls and compliance<br />

monitoring tools and processes<br />

• Advising and preparing statutory and tax reporting<br />

• Supporting internal audit functions<br />

• Providing SOX/JSOX guidance and documentation resources<br />

• Completing valuations, financial due diligence and modeling<br />

• Completing joint venture audits and assurance<br />

• Reviewing and improving enterprise-wide governance, risk<br />

and compliance with advice and resources<br />

• Supporting internal audit functions with expertise and<br />

resources in key areas and geographies<br />

• Providing capital and debt advice<br />

10. World Energy Outlook 2012, IEA.<br />

Africa: EY’s oil and gas tax capabilities<br />

7


Industry issues<br />

Cost management<br />

Oil and gas companies have seen significant increases in<br />

drilling, service, production and operating costs over the past<br />

decade. Economic volatility has put the spotlight directly on cost<br />

management as an area of competitive advantage. The increasing<br />

levels of upstream capital expenditure that are being seen across<br />

the industry are a further incentive for leading organizations to<br />

optimize their costs and working capital.<br />

Managing capital projects<br />

With the industry experiencing a period of major capital investment,<br />

the number of mega-projects with multi-billion dollar budgets has<br />

increased dramatically in recent years. The budgets have become<br />

so large and the technical, construction business and procurement<br />

processes so complex that the difference between average project<br />

management and leading project management processes can often<br />

equate to billions of dollars.<br />

Access to reserves<br />

A vast majority of the world’s oil and gas resources are located in<br />

countries that often restrict access for independent companies.<br />

Even in more “open” economies, access to resources can be limited<br />

by environmental or political restrictions. As a result, exploration<br />

and production activities are moving into increasingly remote and<br />

risky locations. Larger, more technically challenging and capital<br />

intensive projects are leading to more joint ventures, which are<br />

necessary to help companies share the associated risks, technology<br />

and capital. Unconventional resources (such as oil sands, shale gas<br />

and coal bed methane) are becoming an important part of oil and<br />

gas companies’ portfolios as technology makes them cost-effective<br />

and the need for energy makes them an important part of the<br />

supply mix.<br />

How is EY assisting?<br />

• Optimizing working capital and management processes<br />

• Optimizing supply chain processes from both a tax and<br />

operational perspective<br />

• Standardizing complex processes and implementing shared<br />

services<br />

• Rationalizing procurement processes and optimizing spend<br />

• Implementing driver-based planning and making<br />

organizations focus on the key performance metrics that<br />

drive the business<br />

• Reviewing and challenging business case assumptions and<br />

approaches<br />

• Developing and standardizing capital project management<br />

processes<br />

• Providing advice on tax and legal entity structuring<br />

• Providing delivery assurance reviews during critical phases of<br />

the project to provide management with an independent view<br />

of cost/time performance<br />

• Completing contract and procurement compliance reviews<br />

• Reviewing and assessing business cases<br />

• Completing or assuring valuations and data modeling<br />

• Providing new country entry service, including legal entity<br />

and tax structuring<br />

8 Africa: EY’s oil and gas tax capabilities


Industry issues<br />

Portfolio management<br />

The industry is in a period of transition; many factors are<br />

combining to drive high transaction levels across the industry,<br />

thereby driving portfolio rationalization. There are significant<br />

opportunities to acquire downstream assets in many Organization<br />

for Economic Cooperation and Development markets, as we see<br />

a migration of capital from the downstream to the upstream. The<br />

large number of mega-projects in the upstream also has created a<br />

record number of major new joint ventures. In addition, the shale<br />

gas boom in the US has created opportunities that have attracted<br />

the attention of the majors and driven consolidation in this sector.<br />

Combining these issues with a fast-changing regulatory, tax and<br />

economic environment means that developing and implementing<br />

strategic investment and divestment plans has never been<br />

more complex.<br />

IT security<br />

IT security has increasingly become an issue for oil and gas<br />

companies. Disruption to operations caused by cyber attacks on<br />

company systems may compromise safety and operational and<br />

financial performance. Competitive companies are realizing that<br />

they cannot effectively manage risk in a global environment if they<br />

ignore the threat of cyber theft.<br />

Human capital deficit<br />

With new reserves becoming harder to find, the industry is moving<br />

to new frontiers and with the growth in unconventional plays, the<br />

demand for experienced engineers and geologists is increasing.<br />

Despite fewer young engineers and geologists have entering<br />

the industry, and with an aging workforce, there is a premium<br />

on industry experience and the battle for talent will continue to<br />

intensify over the next few years. The problem is exacerbated by the<br />

increasing prevalence of national content laws, which may prevent<br />

areas with sufficient skilled personnel from providing personnel to<br />

those areas with skills shortfalls.<br />

How is EY assisting?<br />

• Providing financial and operational carve-out services<br />

• Providing valuation services<br />

• Providing buy- and sell-side due diligence<br />

• Providing postmerger integration services<br />

• Providing buy- and sell-side tax advice<br />

• Assessing IT audits and security<br />

• Supporting clients to assess and improve risk-related<br />

IT processes<br />

• Developing and implementing customized IT risk<br />

management frameworks and processes<br />

• Developing IT strategy and architecture<br />

• Advising on IT sourcing strategy and processes<br />

• Providing expatriate tax and payroll services<br />

• Advising on global mobility policies and processes<br />

• Advising on remuneration and reward strategies<br />

• Providing business process design and standardization<br />

• Providing shared service design, implementation and<br />

optimization<br />

Africa: EY’s oil and gas tax capabilities<br />

9


Our presence in Africa<br />

At EY, we draw upon our global and local knowledge to help you<br />

retain the confidence of investors, manage your risk, strengthen<br />

your controls, grasp opportunities and achieve your potential. Our<br />

clients find that our “single point of contact” coordination model<br />

significantly enhances their ability to operate, particularly across<br />

multiple countries in Africa.<br />

EY is highly integrated across Africa, which is very significant for<br />

our clients as we run our business by service line, sectors and<br />

functions, instead of by country, which means for you as a client:<br />

We believe that these benefits significantly enhance our quality of<br />

service and speed of response.<br />

EY Africa has a presence in 36 African countries and provides<br />

support in the remaining African continent. In addition, we can<br />

provide support from our London Africa desk and Paris African<br />

Center. Our network throughout the region helps demonstrate that<br />

we are responsive to the needs of our clients, stimulating trade<br />

and enhancing business relationships.<br />

• Consistent quality standards everywhere<br />

• “Single point of contact” service<br />

• The right EY resource irrespective of country location<br />

Morocco<br />

Tunisia<br />

Western Sahara<br />

Algeria<br />

Libya<br />

Egypt<br />

Cape Verde<br />

Senegal<br />

Gambia<br />

Guinea Bissau<br />

Guinea<br />

Sierra Leone<br />

EY office<br />

Mauritania<br />

Liberia<br />

Coted’lvoire<br />

Mali<br />

Burkina Faso<br />

No EY office, but support available<br />

Ghana<br />

Togo Benin<br />

Equatorial Guinea<br />

Sao Tome<br />

Niger<br />

Nigeria<br />

Chad<br />

Central African<br />

Cameroon Republic<br />

Gabon Congo<br />

Democratic<br />

Republic of Congo<br />

Angola<br />

Namibia<br />

Burundi<br />

Botswana<br />

South Sudan<br />

Zambia<br />

South Africa<br />

Sudan<br />

Uganda<br />

Zimbabwe<br />

Rwanda<br />

Tanzania<br />

Swaziland<br />

Lesotho<br />

Ethiopia<br />

Kenya<br />

Eritrea<br />

Mozambique<br />

Malawi<br />

Djibouti<br />

Somalia<br />

Comoros<br />

Madagascar<br />

Seychelles<br />

Reunion<br />

Mauritius<br />

10 Africa: EY’s oil and gas tax capabilities


EY’s oil and gas tax services in Africa<br />

Our African oil and gas tax practice joins a team of more than 60 professionals and provides services to our clients at the local as well as<br />

at the pan-African level, including the following:<br />

Capability<br />

Tax strategy<br />

Tax assessment<br />

Our added value of Africa<br />

Our local, sub-regional and cross-border understanding of tax requirements enables us to advise on development<br />

of tax strategy plans that are aligned with business operations and help to manage tax liabilities.<br />

Our comprehensive and up-to-date understanding of tax laws and issues allows us to provide high-level advice in<br />

all sectors of the industry, including the following matters:<br />

• Exploration and<br />

production<br />

• Downstream<br />

• Development<br />

• Transportation<br />

• Oil service<br />

companies<br />

• Personal<br />

income tax<br />

• Advising on the tax treatment of oil and gas exploration (onshore and offshore)<br />

• Management and tax treatment of petroleum costs<br />

• Refining and manufacturing<br />

• Assistance in a production sharing contract (PSC) negotiations and analysis<br />

• Advising on tax regime applicable to operations of oil and gas companies<br />

• Assessment of tax risk(s) in light of global reporting and consolidation requirements<br />

• Advise on tax treatment and structuring of pipeline works and projects<br />

• Advising on available specific regimes and tax regime applicable to operations<br />

• Customs/tax regime applicable to equipment (such as rigs) and goods<br />

• Entry and exit tax briefings<br />

• Tax regime applicable to staff and rotators<br />

• Advising on compensation and benefits<br />

• Applying for, processing and obtaining tax clearance certificates for all employees<br />

Tax controversy<br />

dispute<br />

resolution<br />

Cross-border tax<br />

efficiency and<br />

M&A tax<br />

Tax functional<br />

efficiency<br />

Tax compliance<br />

Tax policy and<br />

law change<br />

Our local presence and experience allow us to offer our clients assistance in working with tax authorities on tax<br />

audits and other contested tax matters and to help clients resolve tax disputes with regulatory authorities.<br />

We provide technical explanations based on the provisions of the law to the Federal Inland Revenue Service on<br />

issues that require further explanation. Our assistance also includes applying for tax authorities’ rulings on issues<br />

and applying for specific tax regimes.<br />

Our team of professionals at the global, pan-African and local level can advise on tax requirements or agreements<br />

that impact more than one taxing jurisdiction or the movement of goods and/or services from one taxing<br />

jurisdiction to another, such as:<br />

• Domestic and international tax treatment of hydrocarbon-related deals<br />

• Tax advice on transfer of assets<br />

• Structuring of inward investment and advising on exit<br />

• Review of agreement for inward investments (establishment conventions, enabling laws, petroleum contracts)<br />

• Tax consequences on financing<br />

Our credentials include the review of the quality of tax operations to develop improvements or design new<br />

functions that help the client operate more efficiently and effectively. We provide detailed tax analysis of the<br />

issues under request and provide tax-efficient approaches and recommendations to effectively manage tax<br />

charges.<br />

Review of income tax, education tax and capital allowances computations; file the tax computations, together<br />

with self-assessment returns and the audited accounts with the Federal Inland Revenue Service.<br />

As oil and gas is new in many countries, there is an ongoing fiscal policy as well as tax law and regulation change<br />

or reform, particularly in Nigeria, Ghana, Angola, East Africa, etc. We have the competency to assist with these<br />

reforms and law change initiatives by engaging with governments and operators<br />

All of our people have an unwavering commitment to quality service and draw on our consistent global methodologies.<br />

Africa: EY’s oil and gas tax capabilities<br />

11


EY oil and gas tax contacts in Africa<br />

A. Local EY contacts<br />

1<br />

Algeria<br />

Joseph Pagop Noupoue<br />

+23 7 33 502 461<br />

joseph.pagop.noupoue@ey-avocats.com<br />

17<br />

1<br />

15<br />

10<br />

Deana Jouany-d’Almeida<br />

+33 1 55 611205<br />

deana.d’almeida@ey-avocats.com<br />

5<br />

2<br />

Angola<br />

Luis Marques<br />

+244 222 371390/371 461<br />

luis.marques@pt.ey.com<br />

Alexandre Fernandes<br />

+244 222 336 295/371 461<br />

alexandre.fernandes@pt.ey.com<br />

7<br />

13<br />

19<br />

4<br />

9<br />

12<br />

6<br />

2<br />

8<br />

11<br />

23<br />

25<br />

14<br />

20<br />

3<br />

24<br />

18<br />

21<br />

3<br />

Burundi<br />

16<br />

Herbert Gatsinzi<br />

+250 788 305033<br />

herbert.gatsinzi@rw.ey.com<br />

22<br />

4<br />

Cameroon<br />

5<br />

6<br />

Joseph Pagop Noupoue<br />

+23 7 33 502 461<br />

joseph.pagop.noupoue@ey-avocats.com<br />

Yves Moukory-Eyoum<br />

+23 7 33 502 449<br />

yves.moukory@cm.ey.com<br />

Chad<br />

Joseph Pagop Noupoue<br />

+23 7 33502461<br />

joseph.pagop.noupoue@ey-avocats.com<br />

Congo<br />

Crespin Simedo<br />

+242 05 5123434<br />

crespin.simedo@cg.ey.com<br />

Patrick Kongo<br />

+242 539 41 78<br />

patrick.kongo@cg.ey.com<br />

7<br />

8<br />

9<br />

Cote d’ivore<br />

Eric N’Guessan<br />

+255 20 306050/+255 20 211115<br />

eric.nguessan@ci.ey.com<br />

Democratic Republic<br />

of Congo<br />

Crespin Simedo<br />

+242 05 5123434<br />

crespin.simedo@cg.ey.com<br />

Albert-Blaise Akoka<br />

+243 999 30 68 68<br />

albert.akoka@cd.ey.com<br />

Equatorial Guinea<br />

Joseph Pagop Noupoue<br />

+240 333 096719<br />

joseph.pagop.noupoue@ey-avocats.com<br />

Alexis Moutome<br />

Off: +240 333 096719/333 091686<br />

Mob: +240 222 250050/222 215718<br />

alexis.moutome@gq.ey.com<br />

10<br />

11<br />

12<br />

Egypt<br />

Ahmed El Sayed<br />

+20 2 27260260<br />

ahmed.el-sayed@eg.ey.com<br />

Ahmed Hegazy<br />

+20 2 27260260<br />

ahmed.hegazy@eg.ey.com<br />

Ethiopia<br />

Russell Maynard<br />

+255 22 2666853<br />

russell.maynard@tz.ey.com<br />

Gabon<br />

Erik Watremez<br />

+241 742168<br />

erik.watremez@ga.ey.com<br />

Nicolas Chevrinais<br />

+241 742168<br />

nicolas.chevrinais@ga.ey.com<br />

Nicolas Chevrinais<br />

+240 333096719<br />

nicolas.chevrinais@gq.ey.com<br />

12 Africa: EY’s oil and gas tax capabilities


13<br />

Ghana<br />

19<br />

Nigeria<br />

25<br />

Uganda<br />

14<br />

15<br />

16<br />

17<br />

18<br />

Wilfred Okine<br />

+233 244 310 646<br />

wilfred.okine@gh.ey.com<br />

Isaac Sarpong<br />

+233 20 81 111 18<br />

isaac.sarpong@gh.ey.com<br />

Kenya<br />

Russell Maynard<br />

+254 22 2666853<br />

russell.maynard@tz.ey.com<br />

Catherine Mbogo<br />

+254 20 2715300<br />

catherine.mbogo@ke.ey.com<br />

Rachel Muiru<br />

+254 20 2715300<br />

rachel.muiru@ke.ey.com<br />

Libya<br />

Gerry Slater<br />

+962 6 580 0777<br />

gerry.slater@ly.ey.com<br />

Abdulmunaem Elbusaifi<br />

+962 6 580 0777<br />

abdulmunaem.elbusaifi@ly.ey.com<br />

Madagascar<br />

Mialinirina Rasamoelina<br />

+261 20 22 21796<br />

mialinirina.rasamoelina@mu.ey.com<br />

Morocco<br />

Abdeimejid Faiz<br />

+212 5 22957929<br />

abdelmejid.faiz@ma.ey.com<br />

Loubna Saifeddine<br />

+212 5 22957929<br />

loubna.saifeddine@ma.ey.com<br />

Mozambique<br />

Ismael Faquir<br />

+258 21 353 000<br />

+258 21 353 300<br />

ismael.faquir@mz.ey.com<br />

20<br />

21<br />

22<br />

23<br />

24<br />

Abass Adeniji<br />

+234 1 844 9962<br />

abass.adeniji@ng.ey.com<br />

Edem Andah<br />

+234 7087681113<br />

edem.andah@ng.ey.com<br />

Folabi Akanni-allimi<br />

+234 1 2695367<br />

folabi.akanni-allimi@ng.ey.com<br />

Rwanda<br />

Herbert Gatsinzi<br />

+250 788 305033<br />

herbert.gatsinzi@rw.ey.com<br />

David Baliraine<br />

+250 788 305033<br />

david.baliraine@rw.ey.com<br />

Somalia<br />

Russell Maynard<br />

+255 22 2666853<br />

russell.maynard@tz.ey.com<br />

South Africa<br />

Russell Smith<br />

+27 21 4430448<br />

russell.smith@za.ey.com<br />

South Sudan<br />

Russell Maynard<br />

+255 22 2666853<br />

russell.maynard@tz.ey.com<br />

Tanzania<br />

Russell Maynard<br />

+255 22 2666853<br />

russell.maynard@tz.ey.com<br />

Laurian Justinian<br />

+255 22 2667227<br />

laurian.justinian@tz.ey.com<br />

Muhammed Ssempijja<br />

+256 414 343520<br />

+256 414 343524<br />

+256 414 230637<br />

muhammed.ssempijja@ug.ey.com<br />

Allan Mugisha<br />

+256 414343520<br />

+256 414 343524<br />

allan.mugisha@ug.ey.com<br />

David Baliraine<br />

+256 414 343520<br />

david.baliraine@ug.ey.com<br />

B. Global contacts<br />

Alexey Kondrashov<br />

Global Oil & Gas Tax Leader<br />

Tel: +7 495 662 9394<br />

Fax: +7 495 755 9701<br />

alexey.kondrashov@ru.ey.com<br />

James Deiotte<br />

Africa Tax Leader<br />

Tel: +27 11 77 2 3972<br />

Fax: +27 11 772 4972<br />

james.deiotte@za.ey.com<br />

Elias Pungong<br />

Africa Oil & Gas Sector Leader<br />

Tel: +237 33 502 465<br />

elias.pungong@cm.ey.com<br />

Russell J. Maynard<br />

Africa Oil & Gas Tax<br />

Tel: +255 22 266 6853<br />

Fax: +255 22 266 6948<br />

russell.maynard@tz.ey.com<br />

Leon Steenkamp (Dr.)<br />

London Africa Desk<br />

Tel: +44 20 7951 1976<br />

Fax: +44 20 7951 1345<br />

isteenkamp@uk.ey.com<br />

Deana Jouany-d’Almeida<br />

Paris African Center<br />

Tel: +33 1 55 61 12 05<br />

Fax: +33 1 58 47 64 31<br />

deana.d’almeida@ey-avocats.com<br />

Albena Todorava<br />

+258 21 353 300<br />

albena.todorova@mz.ey.com<br />

Justin Liebenberg<br />

South Africa Tax Desk<br />

Tel: +27 11 77 2 3907<br />

Fax: +27 11 772 4907<br />

justin.liebenberg@za.ey.com<br />

Africa: EY’s oil and gas tax capabilities<br />

13


EY | Assurance | Tax | Transactions | Advisory<br />

About EY<br />

EY is a global leader in assurance, tax, transaction and advisory<br />

services. The insights and quality services we deliver help build trust<br />

and confidence in the capital markets and in economies the world over.<br />

We develop outstanding leaders who team to deliver on our promises<br />

to all of our stakeholders. In so doing, we play a critical role in building<br />

a better working world for our people, for our clients and for our<br />

communities.<br />

EY refers to the global organization, and may refer to one or more, of<br />

the member firms of Ernst & Young Global Limited, each of which is<br />

a separate legal entity. Ernst & Young Global Limited, a UK company<br />

limited by guarantee, does not provide services to clients. For more<br />

information about our organization, please visit ey.com.<br />

How EY’s Global Oil & Gas Center can help your business<br />

The oil and gas sector is constantly changing. Increasingly uncertain<br />

energy policies, geopolitical complexities, cost management and<br />

climate change all present significant challenges. EY’s Global Oil &<br />

Gas Center supports a global network of more than 9,600 oil and gas<br />

professionals with extensive experience in providing assurance, tax,<br />

transaction and advisory services across the upstream, midstream,<br />

downstream and oilfield service sub-sectors. The Center works to<br />

anticipate market trends, execute the mobility of our global resources<br />

and articulate points of view on relevant key sector issues. With our<br />

deep sector focus, we can help your organization drive down costs and<br />

compete more effectively.<br />

© 2013 EYGM Limited.<br />

All Rights Reserved.<br />

EYG no. DW0301<br />

CSG/GSC2013/1166169<br />

ED None<br />

In line with EY’s commitment to minimize its impact on the environment, this<br />

document has been printed on paper with a high recycled content.<br />

This material has been prepared for general informational purposes only and is not intended to<br />

be relied upon as accounting, tax, or other professional advice. Please refer to your advisors for<br />

specific advice.<br />

ey.com/oilandgas

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