In the 2023-24 Budget, the government announced the measure ‘Petroleum Resource Rent Tax – Government Response to the Review of the Petroleum Resource Rent Tax (PRRT) Gas Transfer Pricing arrangements’.
This measure included a commitment to remake the Petroleum Resource Rent Tax Assessment Regulation 2015 (the 2015 Regulations).
The Petroleum Resource Rent Tax Assessment Regulations 2023 (the 2023 Regulations) reforms the methodology used in the 2015 Regulations to calculate the price of sales gas that is processed into liquefied natural gas (LNG), including the advanced pricing arrangement (APA) rules, comparable uncontrolled price (CUP) rules and ensuring that tolling arrangements are expressly captured in the regulations.
The 2023 Regulations: Tolling arrangements (the Tolling Regulations) insert deals only with reforms allowing tolling arrangements.
Treasury is currently seeking views from interested parties on the Tolling Regulations which are prioritised ahead of the other components. Consultation on the other components of the 2023 Regulations will commence at a later date.
We also seek stakeholder feedback on priority issues that would inform the ATO’s administrative approach and public advice and guidance on this measure. This also includes feedback on the form of any public advice and guidance necessary to support understanding of the measure.