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Shell Energy - What does this case mean for Exploration in an Income Tax and PRRT context? paper

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Published on 10 Nov 22 by NATIONAL DIVISION, THE TAX INSTITUTE

In Shell Energy the courts have established that ‘exploration’ is not limited to ‘discovery’ but extends to commercial viability. This paper examines the implications of Shell Energy for exploration in an income tax and PRRT context. Topics will include feasibility, FEED, transfer of exploration balances, ZZGN.

Author profile

Martin Fry FTI
Martin Fry, FTI, is the Practice Leader of the Allens Tax Group. Martin represented the taxpayer in Shell Energy v Commissioner of Taxation before the Federal Court, Full Federal Court and High Court. With over 20 years as a Partner of Allens, Martin advises corporations on a broad range of tax issues across a wide range of sectors, including resources, infrastructure, financial services and IP-intensive businesses. Martin has extensive experience in contentious matters, including audits, settlement negotiations, mutual agreement procedure and litigation. Martin has taught Corporate Tax at a postgraduate level at the University of Melbourne. - Current at 28 September 2022
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