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Expenditure on exploration or prospecting paper


This paper covers:

  • tension points in relation to exploration
  • a commercial discovery, or a commercially viable project?
  • exploration or prospecting as defined in Division 40 of the Tax Act 1997
  • meaning of 'feasibility studies to evaluate economic feasibility' of mining
  • the relevance of the final investment decision
  • is it correct to distinguish between a commercial discovery and a commercially viable project?

Author profile:

Martin Fry FTI
Martin has been a Partner in the Allens Tax Group for over fifteen years, and has focused on resource companies, banks and infrastructure projects. He has extensive experience advising on the tax aspects of capital management transactions for ASX-listed companies, most recently in relation to Rio Tinto's 2015 off-market tender share buyback and on-market share buyback. He has also advised APRA-regulated banks on the tax aspects of hybrid equity and subordinated debt instruments. He advises consortia and financiers on the tax aspects of project finance for major infrastructure projects including M2, M5 and M7 motorways, among others. He is a Senior Fellow of the Law Faculty of the University of Melbourne. Current at 12 February 2016 Click here to expand/collapse more articles by Martin FRY.

This was presented at 2010 National Resources Tax Conference.

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Individual sessions

ATO energy & resources update

Author(s):  Michael Smithson

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Case study: Income tax issues for resources projects

Author(s):  Lynette Purcell,  Andrew NELSON,  Jason Mulgat,  Basil MISTILIS

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