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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