世界各国税务体系介绍.docVIP

TaxationofPetroleumpresentation-new_世界各国税务体系介绍 Taxation of Petroleum Resource Exploration and Exploitation Introductory Note The information contained herein has been obtained from the DLA Piper network, from firms with which we have correspondent relationships in countries in which we do not have offices and from other sources. This presentation (i) is intended to provide a summary overview of certain information requested, (ii) is not intended to constitute legal advice with respect to the laws of any particular country and (iii) should not be relied upon as legal advice in structuring investments or conducting activities in any particular country. In certain cases, we have not been able to date to obtain a summary overview of the tax regime of some countries or obtain information with respect to selected issues. We would be pleased to provide the responses at a later time if requested. Focus of Presentation To survey how a Chinese enterprise engaged in petroleum resource exploration and exploitation would be subject to taxation in selected jurisdictions. Note, as a general matter, with respect to the taxation of the Chinese enterprise in those jurisdictions with which China has concluded a bilateral income tax treaty, the Chinese enterprise should be able to obtain the taxation benefits provided by the double taxation agreement. These issues are beyond the scope of this presentation. Jurisdictions surveyed: Australia, Canada, Kazakhstan, Kenya, Indonesia, Iran, Norway, UK and US. Jurisdictions for which information still is required to be obtained: Saudi Arabia and Vietnam. Topics Covered Forms of agreement for petroleum exploration and exploitation. Choice of entity. General income tax rules. Special taxation rules applicable to petroleum operations. Background The income taxation of petroleum transactions is complex and specialized, primarily because of the nature of the industry. The acquisition, exploration, and development of proper