International Taxation of Energy Production and Distribution

Taxation › International

International Taxation of Energy Production and Distribution

By John Abrahamson
Kluwer Law International May 2018

Specifications

ISBN-13
9789041191014
Publisher
Kluwer Law International
Publication
May 2018
Format
Hardback
Jurisdiction
International ? Countri(es) for reference only

Details

International Taxation of Energy Production and Distribution introduces and examines significant international tax issues related to energy production and distribution, extending from the tax regime in the country where the oil, gas, or coal exploration and production activities are located, through to cross-border transportation using pipelines, tankers, and bulk carriers, to the taxation of power stations and electricity transmission and distribution networks. Energy is a major global industry with rapid ongoing changes in areas such as carbon taxes, emissions trading regimes, and the development of renewable energy. The cross-border nature of the industry calls for the thorough, expert, and up-to-date analysis provided in this timely and practical book. Taking a down-to-earth approach to policy and practice in the field worldwide, the author focuses on the international tax framework and the tax regimes in leading energy producing and consuming countries.

What’s in this book:
The taxation issues covered include the following:

  • upstream oil and gas and mining taxes;
  • incentives for renewable energy;
  • carbon taxes and emission trading regimes;
  • dividend, interest, and royalty flows;
  • foreign tax credits;
  • permanent establishments;
  • mergers and acquisitions;
  • taxation issues for derivatives and hedging;
  • transfer pricing;
  • regional purchasing, marketing, service, and intangible property structures;
  • free trade agreements and customs unions;
  • dispute resolution; and
  • tax administration and risk management.

Detailed updates are included on the most recent international tax developments affecting the energy industry, including the OECD Action Plan on Base Erosion and Profit Shifting (BEPS) and the 2017 OECD Transfer Pricing Guidelines. Case studies offer an opportunity to apply international tax analysis to specific examples and gain practice in identifying and discussing relevant international taxation issues.

How this will help you:
As a practical approach to highlight the relevant issues in international energy taxation, this book serves as a springboard for problem-solving and analysis of the related taxation issues. It is a handbook for corporate tax managers and in-house counsel, together with accountants, lawyers, economists, government officials, and academics to navigate confidently through the maze of the taxation issues in the energy industry.

Table of Contents

Preface

CHAPTER 1
Introduction

CHAPTER 2
Overview of International Taxation and OECD BEPS Measures

CHAPTER 3
Tax Treaty Provisions

CHAPTER 4
Examples of Country Fiscal Systems

CHAPTER 5
Upstream Oil and Gas Taxation: Exploration and Production

CHAPTER 6
Tankers and Bulk Carriers

CHAPTER 7
Pipelines

CHAPTER 8
Downstream Taxation: Refineries and Processing Plants

CHAPTER 9
Coal Exploration and Production

CHAPTER  10
Power Stations and Electricity Networks

CHAPTER  11
Renewable Energy: Supply, Funding, and Taxation Incentives

CHAPTER  12
Carbon Taxes and Emissions Trading Schemes

CHAPTER  13
Contractor Services and Permanent Establishments (PEs)

CHAPTER  14
Value Added Tax

CHAPTER  15
Customs Duties and Tariffs

CHAPTER  16
Holding Companies, Dividends, and Profit Distributions

CHAPTER  17
Interest Deductions in Subsidiaries and Thin Capitalisation

CHAPTER  18
Interest Flows and Hybrid Arrangements

CHAPTER  19
Capital Gains, Group Restructures, and Private Equity

CHAPTER  20
Group Procurement Companies

CHAPTER  21
Group Marketing Companies

CHAPTER  22
Group R&D and Intangible Property Companies

CHAPTER  23
Group Treasury and In-House Banking Companies

CHAPTER  24
Group Service Companies

CHAPTER  25
Group Insurance Companies

CHAPTER  26
Mergers and Acquisitions

CHAPTER  27
Asset Leasing

CHAPTER  28
Tax Havens and Controlled Foreign Corporations Rules

CHAPTER  29
Introduction to Transfer Pricing

CHAPTER  30
Transfer Pricing Issues for Energy Production and Distribution

CHAPTER  31
Intangibles and Transfer Pricing

CHAPTER  32
Intra-group Services, Cost Contribution Arrangements, and Transfer Pricing

CHAPTER  33
Loan Financing, Interest Payments, and Transfer Pricing

CHAPTER  34
OECD BEPS and the Changing Tax Environment

CHAPTER  35
Design of Energy Fiscal Systems

CHAPTER  36
General Conclusions

Case Studies

CASE STUDY 1
Renewable Energy: The Offshore Wind Farm Project, Income Flows, and Permanent Establishments (PE)

CASE STUDY 2
Upstream Oil and Gas: The New Production Sharing Contract (PSC)

CASE STUDY 3
Treasury and Finance: The Group Treasury Centre, Loans, and Derivatives

CASE STUDY 4
Mergers and Acquisition: Private Equity Sale of an Electricity Transmission Network

CASE STUDY 5
Group Research and Development (R&D): Cost Contribution Arrangements (CCA)

CASE STUDY 6
Group Technology: The New Battery Storage System and Tax Treaties

CASE STUDY 7
Group Technology: The Solar Power Station, Transfer Pricing, and Mutual Agreement Procedures (MAP)

CASE STUDY 8
Group Marketing: The Liquefied Natural Gas (LNG) Marketing

Appendices

APPENDIX I
OECD Model Tax Convention 2017: Condensed Version

APPENDIX II
North America Free Trade Agreement (NAFTA): Extracts

APPENDIX III
European Union: Union Customs Code

APPENDIX IV
European Union: Union Customs Code

Table of Cases

Table of Statutes and Directives

Table of Treaties and International Agreements

Index

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