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In media release No 2012/166, issued 14 December 2012, the Assistant Treasurer and Minister Assisting for Deregulation, David Bradbury, announced that amendments to the Petroleum Resource Rent Tax (PRRT) law to provide certainty to industry following the Full Federal Court's decision in Esso Australia Resources Pty Ltd v FCT [2011] FCAFC 154 (6 December 2011).

While the case was decided in favour of the Commissioner, the Court also made a number of broader observations regarding the operation of the PRRT law that would have significant implications for the PRRT deductibility of expenditure.

Applying the Court's interpretation in full could have significant financial implications for the industry, resulting in many taxpayers being unable to deduct legitimate expenditures.

As with past amendments to clarify the operation of the PRRT consistent with the underlying policy intent, these amendments will have retrospective effect.


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