{"id":"C2012A00021","name":"Petroleum Resource Rent Tax (Imposition—General) Act 2012","slug":"petroleum-resource-rent-tax-imposition-general-act-2012","collection":"act","jurisdiction":"commonwealth","status":"in_force","isInForce":true,"actNumber":"21 of 2012","makingDate":null,"administeringDepartment":null,"currentVersion":{"id":8330,"registerId":"commonwealth-C2012A00021-current","compilationNumber":null,"startDate":"2026-03-30","status":"InForce","reasons":null,"registeredAt":null},"sections":[{"sectionNumber":"1","sectionType":"section","heading":"Petroleum Resource Rent Tax (Imposition—General) Act 2012","content":"---\nmeta-content-style-type: text/css\nmeta-content-type: application/xhtml+xml; charset=utf-8\n---\n\n?xml version=\"1.0\" encoding=\"utf-8\" standalone=\"no\"?>\n\n![](image.001.png)\n\n \n\n \n\n \n\n \n\n \n\n \n\nPetroleum Resource Rent Tax (Imposition—General) Act 2012\n\n \n\nNo. 21, 2012\n\n \n\n \n\n \n\n \n\n \n\nAn Act to impose a tax in respect of the profits of certain petroleum projects, so far as that tax is neither a duty of customs nor a duty of excise\n\n \n\n \n\n \n\nContents\n\n1 Short title\n\n2 Commencement\n\n3 Incorporation\n\n4 Imposition of tax\n\n5 Rate of tax\n\n6 Act does not impose a tax on property of a State\n\n \n\n![](image.001.png)\n\n \n\n \n\nPetroleum Resource Rent Tax (Imposition—General) Act 2012\n\nNo. 21, 2012\n\n \n\n \n\n \n\nAn Act to impose a tax in respect of the profits of certain petroleum projects, so far as that tax is neither a duty of customs nor a duty of excise\n\n[Assented to 29 March 2012]\n\nThe Parliament of Australia enacts:\n\n1  Short title\n\n  This Act may be cited as the Petroleum Resource Rent Tax (Imposition—General) Act 2012.\n\n2  Commencement\n\n  This Act commences on 1 July 2012.\n\n3  Incorporation\n\n  The Petroleum Resource Rent Tax Assessment Act 1987 is incorporated and is to be read as one with this Act.\n\n4  Imposition of tax\n\n (1) Tax is imposed in respect of the taxable profit of a person of a year of tax in relation to a petroleum project.\n\n (2) However, this section imposes that tax only so far as it is neither a duty of customs nor a duty of excise within the meaning of section 55 of the Constitution.\n\n (3) This section applies in relation to the year of tax beginning on 1 July 1986 and later years of tax.\n\n5  Rate of tax\n\n  The rate of tax in respect of the taxable profit of a person of a year of tax in relation to a petroleum project is 40%.\n\n6  Act does not impose a tax on property of a State\n\n (1) This Act does not impose a tax on property of any kind belonging to a State.\n\n (2) In this section, property of any kind belonging to a State has the same meaning as in section 114 of the Constitution.\n\n[Minister’s second reading speech made in—\n\nHouse of Representatives on 2 November 2011\n\nSenate on 7 February 2012]\n\n(228/11)\n\n \n","sortOrder":0}],"analysis":{"flash_summary_failed":{"failed":true,"reason":"A positive credit balance is required for all requests, including BYOK, so fallback providers remain available. Add credits at https://vercel.com/d?to=%2F%5Bteam%5D%2F%7E%2Fai%3Fmodal%3Dtop-up to continue.","source":"analysis-cron"},"flash_summary":{"complexity_score":3,"scope_assessment":{"changed":false,"description":"This Act is narrowly focused: it imposes the PRRT, sets the headline 40% rate, specifies temporal scope (from 1 July 1986) and incorporates the 1987 Assessment Act for the detailed rules. It does not materially expand the categories of taxpayers or the tax base within its text; the substantive scope and measurement are delegated to the incorporated Assessment Act. The only notable scope feature is the retrospective temporal reach to 1 July 1986 (section 4(3)), but that appears intended to align the imposition with the policy framing of the PRRT rather than to broaden the law beyond its original purpose. Therefore, the Act has not grown significantly beyond its original, narrowly defined purpose of imposing the PRRT."},"complexity_factors":["Very short instrument (6 sections)","Incorporates the Petroleum Resource Rent Tax Assessment Act 1987 (section 3) — detailed definitions and calculation rules live in that other Act","Clear headline rule with a single tax rate (40%) (section 5)","Temporal cross‑reference: applies to years of tax from 1 July 1986 (section 4(3)) — retrospective/timing effect increases legal complexity","Two constitutional cross‑references: limits to avoid being an excise/customs duty (section 4(2), referencing Constitution s55) and exclusion of State property (section 6, referencing Constitution s114)","Practical complexity arises from reliance on external Act rather than from internal conditional logic (few internal defined terms or nested exceptions in this Act)"],"plain_english_summary":"The Act levies the Petroleum Resource Rent Tax (PRRT) at 40% on taxable profits from specified petroleum projects, with liability, measurement and administration governed by the incorporated Petroleum Resource Rent Tax Assessment Act 1987. It applies to income years from 1 July 1986 and commenced 1 July 2012.\n\nIt affects companies and other participants in petroleum projects (who bear the tax) and Commonwealth revenue authorities (who administer it), while expressly excluding State property and denying the charge is an excise or customs duty."},"kimi_summary":{"content_quality":"ok","complexity_score":2,"scope_assessment":{"changed":false,"description":"This is a standard imposition Act with a narrow, specific purpose: to impose the tax at a fixed rate while avoiding constitutional issues. It has not expanded beyond its original intent of serving as the taxing mechanism companion to the Assessment Act."},"complexity_factors":["Only 6 sections total","No defined terms in the Act itself (relies entirely on the incorporated Assessment Act for definitions)","Single straightforward rate (40%) with no conditions or tiers","Minimal conditional logic (only one exception in section 4(2) regarding constitutional limitations)","Heavy reliance on incorporation by reference to the Petroleum Resource Rent Tax Assessment Act 1987 for substantive content"],"plain_english_summary":"This law creates a 40% tax on profits from certain petroleum (oil and gas) projects in Australia. It works together with the Petroleum Resource Rent Tax Assessment Act 1987, which contains the detailed rules about how to calculate those profits. The tax applies to years starting from 1 July 1986 onwards. Importantly, the law is carefully worded to avoid being classified as a customs duty or excise tax (types of taxes that the Constitution restricts), and it explicitly protects state government property from being taxed."}},"importantCases":[],"_links":{"self":"/api/acts/petroleum-resource-rent-tax-imposition-general-act-2012","history":"/api/acts/petroleum-resource-rent-tax-imposition-general-act-2012/history","analysis":"/api/acts/petroleum-resource-rent-tax-imposition-general-act-2012/analysis","conflicts":"/api/acts/petroleum-resource-rent-tax-imposition-general-act-2012/conflicts","importantCases":"/api/acts/petroleum-resource-rent-tax-imposition-general-act-2012/important-cases","documents":"/api/acts/petroleum-resource-rent-tax-imposition-general-act-2012/documents"}}