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Exploration issues paper


What comprises exploration activity and exploration expenditure is a critical issue for resource companies for both income tax and resource rent tax purposes. While exploration expenditure deductions have been a feature of the tax law for decades, ensuring the exploration deduction provisions operate as intended is as important to the industry now as it has ever been.

This paper examines topical exploration and related issues, including:

  • the policy behind exploration deductions
  • differences between corporate tax, PRRT and MRRT classification of exploration
  • common law vs extended law interpretations of exploration
  • the asset “first use” concept for income tax
  • recent precedent and ATO views
  • where to from here?

Author profiles

Shigeaki Inoue CTA
Shigeaki is a Senior Manager at Ernst & Young. - Current at 17 October 2012
Basil Mistilis
Basil is a Partner with Ernst & Young and is the leader of Ernst & Young’s tax practice in Perth. A qualified chartered accountant with more than 20 years experience, Basil specialises in providing tax advice to companies in the resources industry. Basil has participated in government liaison on key tax policies affecting the resources industry (including resource rent taxes) and has worked on submissions for various industry bodies. - Current at 17 October 2102
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Andrew Nelson CTA
Andrew is a Partner with Ernst & Young’s Perth tax practice with more than 11 years’ experience in domestic and international tax consulting. Andrew is an integral member of Ernst & Young’s Oil & Gas Advisory Group, consulting with junior and large oil and gas companies, and has particular expertise in Petroleum Resource Rent Tax. - Current at 17 October 2012


This was presented at 2012 National Resources Tax Conference .

Get a 20% discount when you buy all the items from this event.

Individual sessions

Preparing for tax disputes

Author(s):  John W DE WIJN,  Andrew BROADFOOT

Materials from this session:

MRRT - Where are we now?

Author(s):  James STRONG

Materials from this session:

Keeping our ear to the ground - The ATOs administration of the resource rent taxes

Author(s):  Stephanie MARTIN

Materials from this session:

Further details about this event:


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