Petroleum Resource Rent Tax Assessment Regulation 2015
38Phase costs and upstream and downstream costs
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38 Phase costs and upstream and downstream costs
(1) For the purposes of step 7 of the residual pricing method, the included direct and indirect costs are attributed to the various phases or stages of the operation in accordance with this section. Attributing costs to phases (2) For each phase of the integrated operation, each included direct cost that can be wholly attributed to the phase is a phase cost for the phase. (3) If a direct cost for the integrated operation cannot be wholly attributed to activities of a single phase: (a) the cost is taken to be made up of separate costs for each phase, each of the amount (if any) that can reasonably be apportioned to that phase; and (b) each of those costs is attributed to the appropriate phase. Attributing costs to stages (4) Each included indirect cost for the integrated operation is taken to be made up of 2 costs of equal amounts, of which one is attributable to the upstream stage and one to the downstream stage.
Note: Section 43 does not apply to these costs, so that they are not reduced because of the multiple use of a phase.
(5) A cost that is a phase cost of a phase in the upstream stage, or an indirect cost allocated to the upstream stage by subsection (4), is an upstream cost. (6) A cost that is a phase cost of a phase in the downstream stage (which will include marketing and selling costs), or an indirect cost allocated to the downstream stage by subsection (4), is a downstream cost.