Petroleum Resource Rent Tax Assessment Regulations 2024
For the purposes of step 7 of the residual pricing method, the included direct and indirect costs are attributed to the various phases or stages of the relevant operation in accordance with this section.
Attributing costs to phases
42(2)
For each phase of the relevant operation, each included direct cost that can be wholly attributed to the phase is a phase cost for the phase.
42(3)
If a direct cost for the relevant operation cannot be wholly attributed to activities of a single phase: (a) the cost is taken to be made up of separate costs for each phase, each of the amount (if any) that can reasonably be apportioned to that phase; and (b) each of those costs is attributed to the appropriate phase.
Attributing costs to stages
42(4)
Each included indirect cost for the relevant operation is taken to be made up of 2 costs of equal amounts, of which one is attributable to the upstream stage and one to the downstream stage.
Note:
As these costs are not phase costs, section 49 does not apply to them, so they are not reduced because of the multiple use of a phase.
42(5)
A cost that is a phase cost of a phase in the upstream stage, or an indirect cost allocated to the upstream stage by subsection (4) , is an upstream cost.
42(6)
A cost that is a phase cost of a phase in the downstream stage (which will include marketing and selling costs), or an indirect cost allocated to the downstream stage by subsection (4) , is a downstream cost.
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