International Taxation of Energy Production and Distribution

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, problem-solving 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.

The book introduces and analyses 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. 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.

This book will be of significant value to corporate tax managers and in-house counsel, together with accountants, lawyers, economists, government officials, and academics connected with the energy industry and related international taxation issues.