Keiran – we talked and talked but we can talk no more.
Over the past several days, the Commissioner issued:
- A draft miscellaneous taxes ruling on the taxation aspects of immediate transfer farm-out arrangements.
- a draft miscellaneous taxes ruling on the taxation aspects of deferred transfer farm-out arrangements.
The fact that both GST and income tax are dealt with in one ruling is heartening. The characterisation and value of what is given (consideration) and what is obtained (the supply) is significant – and needs to be considered in the light of other transactions where “known knowns” and “known unknowns” are concerned.
Maybe the analysis needs to be compared to earn outs and assumption of liabilities.