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Asset unitisation paper

Published on 24 Oct 18 by WESTERN AUSTRALIAN DIVISION, THE TAX INSTITUTE

This paper covers:

  • the fiscal environment
  • alternate approaches to structuring unitisations
  • direct asset unitisation involving UJV
  • direct asset unitisation involving a partnership
  • incorporated unitisation
  • synthetic asset unitisation.

Author profiles

James O'Reilly
James is PwC Australia's Tax Leader for Energy & Mining. He is based in Brisbane and specialises in advising clients investing in the Australian resources industry, with a particular focus on the coal, oil & gas and precious metal industries. James has extensive knowledge of the tax issues relevant to resource operations, including the tax implications associated with the various stages of a mining operations' life cycle (i.e. exploration, development, operation and cessation), the establishment of joint venture arrangements, M&A activity and the application of State based royalty regimes. Part of James' focus is advising inbound multinationals on their Australian investments, including advising on the tax implications associated with alternate structures for inbound investment and financing. - Current at 04 October 2017
Janelle O'Hare
Janelle is the National Tax Leader for Energy and Resources in PwC. She is a partner in the Corporate Tax team based in Brisbane. She has over 19 years of tax consulting experience. Janelle primarily advises a broad range of operators, joint venture participants and investors in the energy and resources industry, with a focus on the oil and gas sector. Janelle has significant experience in relation to the application of the PRRT regime and has advised on the application of the regime to every major offshore and onshore project in Australia. She has also worked with the ATO on issues arising from the transition of the regime to the onshore projects. - Current at 04 September 2020
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Jess Fantin
Jess is a Director at PricewaterhouseCoopers. - Current at 21 November 2018
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This was presented at 2018 National Resources Tax Conference .

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Individual sessions






The R&D tax incentive - The shifting policy & regulatory landscape

Author(s):  Liz Dallimore

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