Oil and gas upstream sector across Europe · 2020-03-23 · Oil and gas upstream in Europe”issued in February and September 2015, covering 2013 and 2014, together with our latest

An overview on royalties and similar taxesOil and gas upstream sector across Europe

April 2018

© 2018. For more information, contact Deloitte Romania 2

Contents

Background and methodology 3

Executive summary 6

General overview of Romania and other European countries 8

Graphical view of oil & gas royalties and similar taxes 16

Oil & gas production summary 20

Country snapshots 23

Fiscal regime changes 51

Limitations and acknowledgements 54

References and resources 57

Conversion table 64

3© 2018. For more information, contact Deloitte Romania

Background and methodology


Asociația Română a Companiilor de Explorare și Producție Petrolieră (“ROPEPCA”) has requested us toconduct an analysis with respect to the level of royalties and similar taxes applicable to the oil & gasupstream sector in Europe, as at 31 December 2016.

This analysis has taken into account the position of the European countries for the purpose ofestablishing a comprehensive and comparative overview of the fiscal environment and the relatedmarket conditions in relation to the upstream oil and gas industry. Furthermore, most Europeancountries have a specific tax regime for oil & gas industry, which includes either royalties and / orother specific taxes, or an increased corporate income tax rates for operators activating in this sector.

The report should be considered within the limitation that every country has a different tax regime.The effective royalties and similar specific taxes may differ from nominal rates. These are driven bynational priorities and market reality.

We have performed an analysis regarding the effective tax rates in different European countries basedon the information available as at 31 December 2016, except where explained otherwise. Thecomputation of the effective tax rate for each country had in view the value of the royalties andspecific upstream taxes paid by the main players divided by the revenues obtained from theproduction and sale of oil & gas, for which public information was available.

Background and methodology


Given that in most countries operators present the relevant data in a combined manner (i.e., figuresincluding both oil and gas), the study also presents the effective tax rates for oil & gas upstreamactivities in each country. For Romania, as one of the main players in the industry is primarilyproducing gas, we were able to distinguish between the effective tax rate for gas and oil activities.

The results of this study may be read in conjunction with our previous reports - “Observation onroyalties and similar taxes – ‘an updated overview’. Oil and gas upstream in Europe” issued inFebruary and September 2015, covering 2013 and 2014, together with our latest report “An overviewon royalties and similar taxes - Oil and gas upstream sector across Europe” issued in March 2017,covering 2015.

Background and methodology (cont’d)


Executive summary


Yet again, 2016 proved itself as a challenging year for the oil and gas industry, asthe financial results were impacted by the continued low price environment.However, both the oil and gas prices recovered significantly at the end of the year,as compared to the beginning of 2016.

In countries with a specific taxation regime adapted to market prices (e.g., taxationon profits), for example Denmark, Norway, Netherlands, the continuing decrease ofprices led to a lower effective tax rate. Moreover, some of the countries respondedto these market conditions by relaxing their fiscal regimes in relation to the oil andgas specific taxes (e.g., Denmark, Hungary and the United Kingdom).

Despite the overall descending trend among other European countries (theaverage rate for royalty and specific taxes in the European upstream sector beingreduced to 8.8% in 2016, compared to 9.8% in 2015), the effective tax rate inthe Romanian upstream sector has further increased to 17.4% in 2016 (ascompared to 16.9% in 2015). This is mainly due to increased share of gas whichhas a higher taxation level compared to oil.

Similar to 2015, the computation of the supplementary tax for gas was notcorrelated with the actual prices on the gas market.

There are also other European countries with a slight increase in the effective taxrate, derived either from fixed components (e.g., in France, a fixed tax per tone), orfrom an increase of nominal tax level (e.g., Poland).

Executive summary


General overview of Romania and other European countries


The Romanian onshore upstream oil and gas sector is very mature after more than 150 years of activity and it may be characterized as follows:

In Romania there are over 400 oil & gas fields and more than 13,000 producing wells, however it has one of the lowest rates of production perwell among all European Countries;

The oil and gas fields are very fragmented and identification of new reserves often requires drilling at very deep horizons. Moreover,approximately 21% of crude oil production is obtained using enhanced oil recovery techniques and heavy oil represents more than 35% of oilproduction. Therefore, massive investments are required to improve extraction technologies (increase of reservoir pressure, deep drilling etc.)and increase recovery factor from mature fields in order to cover the national demand;

Significant amounts (i.e., approx. EUR 3.7 billion during the period 2014 - 2016) are spent annually by the onshore upstream oil and gasexploration and production sector in Romania, in order to bring new wells into production or to invest in the existing technology and to increasethe recovery rates of mature oil and gas fields;

The investments performed should be directly linked with the existing level of employment in the sector. According to EU Energy Statistics, theupstream oil and gas sector in Romania has the largest number of direct employees among the EU countries (more than 23 thousands directemployees out of 77 thousands employees in all EU countries). It covers a wide range of blue-collar professionals, but also engineers, earthscientists, environmental, health and safety specialists, lawyers, IT specialists, accountants. Moreover, studies show that investments in the oiland gas sector generate a significant number of indirect jobs;

Last but not least, the upstream oil and gas industry brings an important contribution in the Romanian economy, in terms of taxes paid to theState Budget, as well as the impact that it has on other sectors covering oil refining and electricity, heat production etc.


General outline over Romania


Based on our computations, the effective royalty and similar tax rate increased from 16.9% in 2015 to 17.4% in 2016 and decreased in 2017 to13.9%, mainly due to the elimination of the construction tax, starting with January 2017.

The effective tax rate was computed as an average between the observable royalty and similar taxes paid (oil and gas royalties, supplementarytaxes* and construction tax**), reported to the revenues obtained by the main Romanian players - SNGN Romgaz SA (21.2% - effective tax rate in2016 and 18.9% in 2017) and OMV Petrom SA (15.9% - effective tax rate in 2016 and 11.6% in 2017).

We noted that the effective tax rate for the upstream gas activity is much higher than the effective tax rate for the upstream oil activity (i.e., in 201621.2% effective tax rate for Romgaz, which primarily produces gas, in comparison to 15.9% effective tax rate for OMV Petrom SA that has acombined production of oil and gas). The difference between the effective tax rate for the upstream gas activity and upstream oil activity is mainlydriven by the supplementary tax on gas.

Despite the decrease of the nominal rate from 1.5% to 1% for construction tax starting with 2015, which was also prolonged in 2016, the higheroverall effective tax rate for the oil and gas upstream activity in 2016 is mainly the result of:

the increased share of gas which has a higher taxation level compared to oil;

The extension of 60% gas supplementary tax applicability, which maintains the high taxation level;

the discrepancy between the threshold used for computing the gas supplementary tax (72 lei / MWh) with the realized gas prices thatoscillated below this threshold;

Although the effective tax rate in 2017 decreased with 3.5% compared to 2016, State Budget revenues from the two main upstream playersremained approx. the same (1.6 vs. 1.7 billion lei).

*Supplementary taxes include a tax of 60% applied to additional revenues resulted from the deregulation of natural gas prices and a tax of 0.5% applied torevenues resulted from the crude oil exploitation

**Corporate income tax was not included.


General outline over Romania



General overview of other European countries

An arithmetical average for the other European producing countries wasalso computed, resulting in an effective tax rate of 8.8% or 6.9% (byexcluding the Groeningen field). Thus, a slightly decrease of the effectivetax rate at European level can be observed as compared to 2015 (9.8%,respectively 7.9% without the Groeningen field).

The average observable royalties and similar taxes as of 2016 compared to2015 for certain European countries are presented below.

Norway

The average observable royalty and similar tax rate decreased from 13.9%in 2015 to 7.3% in 2016. Although production increased, the pricecontinued to decline in 2016, leading to lower income as compared to 2015and thus, challenging the profitability of the oil and gas industry.

Denmark

The average observable royalty and similar tax rate was of 3.1 % in 2016,by comparison to 9.2% in 2015. The difference resulted from a productiondecrease of approx. 13% in 2016, connected also with a lower profitabilitymainly due to lower oil prices.


Hungary

The average observable royalty and similar tax rate decreased from18.1% in 2015 to 16.5% in 2016 due to the continuous decrease incrude oil prices, which in return led to a decrease of the revenues.This decrease of effective tax rate is mainly due to lower applicableroyalty nominal rates which are linked to a significant extent tocrude oil prices.

Poland

The average observable royalty and similar tax rate increased from0.9% (2015) to 3.5% in 2016. Such increase resulted from thegrowth of the mineral fees applicable to the oil & gas production.

Greece

The average observable royalty and similar tax rate increased fromnil to 2.3% due to higher production levels that led to an increase ofthe applicable royalty rates.

Netherlands

The average observable royalty and similar tax rate in relation to smallfields increased from 2.8% in 2015 to 3.6% in 2016. The Groeningenarea recorded a further decrease as compared to last year, from 60.8%in 2015 to 51.9% in 2016. Such decrease may be correlated to thedecision of the Minister of Economic Affairs to further decrease theproduction within the Groeningen field due to multiple recentearthquakes within the area. Other main factor contributing to thisdecrease is the lower profitability due to decline in oil prices.

Ireland

The average observable royalty and similar tax rate dramaticallydecreased from 4.5% in 2015 to 0.1% in 2016, due to start of Corribfield production, which is not subject to royalties and does not triggercorporate income tax in 2016.


General overview of the European countries




Germany

The average observable royalty and similar tax rate decreased from14.5% (2015) to 11.7% for the main German exploitation areas(Niedersachsen and Schleswig – Holstein regions). A slightly decreasewas also recorded in Germany’s other lands from 2.5% in 2015 to 2.1%in 2016, due to the lower revenues obtained as a consequence of thecontinuous lower crude oil price, as well as the lower royalties andsimilar taxes paid to the German Government.

Albania

The average observable royalty and similar tax rate slightly decreasedfrom 14% in 2015 to 13.7% in the first semester of 2016, mainly dueto the specifics of the royalty regime which tends to decrease theeffective tax rate over time. Due to the limited publicly availableinformation, we were only able to compute the effective tax rate basedon the information available as of 30 June 2016.


Spain

The average observable royalty and similar tax rate of 1.4% from2016, includes mainly royalties that entered into force starting withJanuary 2016. The decrease of the effective tax rate was directlyinfluenced by a decrease of the profitability due to decline of oilprices.

Italy

The average observable royalty and similar tax rate decreased to7.9% by comparison to 8.7% in 2015, due to a higher share ofsmall fields in the total production.

Austria

The average observable royalty and similar tax rate increased to18.4% by comparison to 16.9% in 2015.

Serbia

The average observable royalty and similar tax rate for 2016remained the same compared to 2015, respectively 2.9%.



United Kingdom

Similar to 2015 (-1.1%), the average observable royalty and similartax rate had a negative value for 2016 (-1.6%), being influenced bythe following factors:

elimination of the petroleum revenue tax (PRT), starting with 1January 2016 and reimbursement of the paid PRT towardsoperators;

decrease of the supplementary charge (SC) from 20% in 2015 to10% in 2016;

increase with 40% of the corporation tax repayments, reflecting thehigher amount of losses that were carried back, in particulardecommissioning losses;

significant investments performed in both existing developmentsand new projects, resulting in continuing high levels of expenditure.




Lithuania

The average observable royalty and similar tax rate slightly increasedfrom 13.4% in 2015 to 13.8% in 2016.

France

The average observable royalty and similar tax rate increased to 11%by comparison to 9.6% in 2015, considering the method of computingthe royalties, as fixed amount per tone.

***

Regarding Czech Republic, Slovakia and Slovenia, we included only thenominal tax rates for oil and gas companies, as no public informationwas available to compute an effective tax rate.

Due to lack of public information, we have considered the averageobservable royalty and similar tax rate similar to 2015 for Bulgaria,given that no major tax amendments were implemented for 2016.


Graphical view of oil and gas royalties and similar taxes


15%

9.1%

11.6%

16.9%

7.5%

9.8%

17.4%

6.9%

8.8%

13.9%

Romania Rest of Europe (except for Netherlands Groeningen*) Rest of Europe

2014 2015 2016 2017

Average rate for royalties and specific taxes in the upstream sector

Region 2014 2015 2016 2017

Romania 15% 16.9% 17.4% 13.9%

Rest of Europe (except for Netherlands Groeningen)

9.1% 7.5% 6.9% N/A

Rest of Europe 11.6% 9.8% 8.8% N/A

* Netherlands Groeningen is a giant natural gas field, the largest in Europe, the tenth-largest in the world and as a result, it has a separate fiscal regime. In order to preserve the reserves present in the Groeningen

field, the Dutch Ministry decided to promote the exploitation of the Netherland's small fields by granting fiscal incentives specific for them.


Graphical split of the Romanian oil and gas taxes and royalties as percentage of the effective tax rate

8.2%

6.5%

2.2%

2015

Oil and gas taxes and royalties as percentage of the effective tax rate:

2015 2016 2017

Royalties* 8.2% 8% 7.7%

Supplementary taxes** 6.5% 6.4% 6.2%

Construction tax*** 2.2% 3% N/A

* During the period mentioned above (2015 – 2017), royalties are computed based on the value of production of oil and gas by applying a rate between 3.5% -13.5% for oil and 3.5% - 13% for natural gas; for more information please consult the country snapshot for Romania.

** Supplementary taxes during the period mentioned above (2015 – 2017), include a tax of 60% applied to additional revenues resulted from the deregulation of natural gas prices and a tax of 0.5% applied to revenues resulted from the crude oil exploitation.

*** Construction tax of 1% is applied to the gross book value of the structures owned by taxpayers (e.g. gas and oil wells, piping networks). However, starting with 2017 this tax was abrogated, leading to an overall decrease of the effective royalty and similar tax rate.

8%

6.4%

3%

2016

Royalties

Supplementary taxes

Construction tax

7.7%

6.2%

2017


-1.1

4.5

1

2.2 2.5

0

2.9

9.2

0.9

2.8

5 5

7.1

13.9

8.7

109.6

14.5

12.5

1413.4

18.1

16.9 16.9

-1.6 0.11.4 2.1 2.3

3.13.5 3.6

7.3 7.9

1111.7 13.7

13.8

16.5

17.4 18.4

Effective rate (2015) Effective rate (2016) Effective rate (2017) Average rest of Europe (2016) Average rest of Europe, except for Netherlands Groeningen (2016)

60.8

Observable oil and gas royalties and similar taxes across Europe

8.8%

6.9%

51.9

* Netherlands Groeningen is a giant natural gas field, the largest in Europe, the tenth-largest in the world and as a result, it has a separate fiscal regime. In order to preserve the reserves present in the Groeningen

field, the Dutch Ministry decided to promote the exploitation of the Netherland's small fields by granting fiscal incentives specific for them.

13.9


Oil & Gas production summary


Production profile per country - 2016


*Gas production for 2015

No. CountryOil & gas reserves

(mn. boe)

Oil reserves

(mn. boe)

Gas reserves

(mn. boe)

Gas reserves

(bcm)

Total production (mn. boe /

year)

Oil production (mn. boe /

year)

Gas production (mn. boe /

year)

Gas production

(bcm / year)

Production oil & gas / field (boe /

day)

Production oil & gas / well (boe /

day)

Year of first production

1 Romania 1,263.5 600.0 663.5 105.5 94.6 29.9 64.7 10.3 622.8 23.2 2nd half of 19th century

2 Greece 16.2 10.0 6.2 1.0 1.2 1.2 0.03 0.004* 1,080.4 162.1 2nd half of 20th century

3 Norway 18,284.4 6,610.6 11,673.9 1,856.0 1,463.5 729.7 733.7 116.7 47,732.4 3,039.8 2nd half of 20th century

4 Hungary 73.5 25.1 48.4 7.7 19.5 8.3 11.1 1.8* N/A N/A First half of 20th century

5 Germany

430.6 132.5 298.2 47.4

71.8 17.3 54.6 8.7 1,549.1 134.8

Schleswig-Holsteinand Lower Saxony

67.0 15.4 51.6 8.2 1,716.6 154.6 2nd half of 19th century

Other fields 4.8 1.9 2.9 0.5 653.4 48.0 2nd half of 19th century

6 Netherlands

4,927.1 140.9 4,786.2 760.9

325.4 7.1 318.2 50.6 2,645.7 426.6

Groningen 183.1 - 183.1 29.1 501,598.4 1,843.0 2nd half of 20th century

Small fields 142.3 7.1 135.1 21.5 1,875.8 267.0 First half of 20th century

7 Irland 62.3 - 62.3 9.9 17.7 - 17.7 2.8 967.5 268.8 2nd half of 20th century

8 Poland 651.4 137.7 513.7 81.7 50.4 11.7 38.7 6.1* 608.2 69.0 2nd half of 19th century


Production profile per country - 2016



No. CountryOil & gas reserves

(mn. boe)

Oil reserves

(mn. boe)

Gas reserves

(mn. boe)

Gas reserves

(bcm)

Total production (mn. boe /

year)

Oil production (mn. boe /

year)

Gas production (mn. boe /

year)

Gas production

(bcm / year)

Production oil & gas / field (boe /

day)

Production oil & gas / well (boe /

day)

Year of first production

9 Albania 173.5 168.3 5.2 0.8 8.5 8.3 0.2 0.03* 2,329.7 N/A First half of 20th century

10 United Kingdom 4,046.7 2,754.7 1,292.0 205.4 605.6 370.6 235.0 37.4 5,152.4 479.6 2nd half of 19th century

11 Denmark 739.3 551.0 188.3 29.9 80.3 51.2 29.1 4.6 11,576.9 477.1 2nd half of 20th century

12 Austria 95.1 45.4 49.7 7.9 13.8 5.9 7.9 1.3 226.6 46.8 First half of 20th century

13 Italy 917.0 579.0 338.0 53.7 65.4 27.5 37.9 6.0 886.5 218.9 2nd half of 19th century

14 Serbia 380.5 77.5 303.0 48.2 11.0 7.3 3.7 0.6 602.1 40.5 First half of 20th century

15 France 133.4 78.4 55.0 8.7 9.2 9.1 0.2 0.03* 328.2 N/A First half of 20th century

16 Spain 166.0 150.0 16.0 2.5 1.4 1.0 0.4 0.1 353.7 N/A 2nd half of 20th century

17 Lithuania 12.0 12.0 - - 0.7 0.7 - - 133.3 52.6 2nd half of 20th century

18 Bulgaria 50.6 15.0 35.6 5.7 1.0 0.4 0.6 0.1 N/A N/A 2nd half of 20th century

19 Czech Republic 39.9 15.0 24.9 4.0 3.9 2.3 1.6 0.2* N/A N/A First half of 20th century

20 Slovakia 98.0 9.0 89.0 14.1 0.7 0.1 0.6 0.1* N/A N/A First half of 20th century

21 Slovenia - - - - 0.03 0.0 0.03 0.005 N/A N/A First half of 20th century


Country snapshots


Oil & Gas royalties and similar taxes

Royalties are computed as a percentage applied to the value of gross extractedproduction, as follows:

Starting with February 2018, the reference price used to determine gasroyalties, will take into consideration the average price of the previous monthset by the Central European Gas Hub (CEGH hub, Baumgarten, Austria). This isthe day-ahead price and not the price of long term contracts, being veryvolatile according to the market conditions, temperature, accidents, etc.Moreover, this price includes also the transport tariff and the entry cost for theCEGH hub.

Day Ahead prices in general do not reflect the Romanian gas market practiceswhich are mainly based on long-term contracts which are not subject to suchvolatilities as Day Ahead prices. Also, transport and entry tariffs into theAustrian gas system will further increase reference prices artificially.

As royalties are computed based on the maximum between realized sale priceand reference price, if CEGH hub price will be higher than the realized saleprice, the effective gas taxation will increase.

Country snapshotRomania

Other similar taxes to royalties apply to upstream oil & gas players inRomania, including:

Supplementary tax of 60% applied to additional revenues resulted fromthe deregulation of natural gas prices;*

Supplementary tax of 0.5% applied to revenues resulted from the crudeoil exploitation – applicable until 31 December 2018;

* An increase of tax rate to 80% for the revenues above 85 lei/ MWh.

Construction tax of 1% is applied to structures owned by taxpayers (e.g.gas and oil wells, piping networks)**;

** The construction tax was abrogated starting with 2017

Type Gross production Royalty rate

Oil (th tons/ quarter)

< 10 between 10 – 20 between 20 – 100 > 100

3.5% 5% 7% 13.5%

Gas (mn cubicmeters /quarter)

< 10 between 10 – 50 between 50 – 200 > 200

3.5% 7.5% 9% 13%


Country snapshotRomania (continued)

Production

64.7

600.0663.0

29.9

Oil Gas

Oil & gas production/ year and reserves, 2016, Mn boe

0

100

200

1992

2014

2006

2002

1994

2012

2004

1996

2010

2016

1998

1990

2000

2008

Production of Crude Oil, NGPL and other liquids

0

500

1990

2000

1998

1996

1994

1992

2014

2010

2008

2016

2012

2004

2006

2002

Oil & gas evolution, (Thousand Barrels per Day)

Production

Reserves

Source: EIA, Romanian Energy Regulatory Authority

Source: EIA

Production of Dry Natural Gas

CompanyAvg. production/ field (boe/ day)

Avg. production/ well (boe/ day)

OMV Petrom 714 22

Romgaz 530 24

Source: OMV Annual Report 2016, Romgaz Annual Report 2016


Country snapshotGreece


For existing producing fields, the production sliding scale royalty rates areincluded in concession agreements as follows:

The royalty rates from the new concession agreements are calculateddepending on the value of the R-factor (cumulated gross inflows divided bycumulated total outflows), generally as follows:

Royalty payments are deductible from a corporate income tax perspective.

Production

Production (barrels / day) Royalty rates

< 2,500 0%

Between 2,501 – 5,000 3%

Between 5,001 – 10,000 6%

> 10,001 10%

R-factor value Royalty rates

< 0.5 Negotiable, but not less than 4%

Between 0.5 - 1 Negotiable

Between 1 – 1.5 Negotiable

Between 1.5 - 2 Negotiable

> 2 Negotiable, but not less than 20%

1,16

Gas*

6,20

Oil

0,03

10,00


Source: EIA

Production

Reserves


0

10

20

2002

1992

2000

1998

1996

1990

1994

2010

2006

2004

2008

2014

2016

2012

0

1

2

2008

2014

2010

2012

2016

2006

2002

2000

1998

2004

1996

1994

1992

1990

Source: EIA



Avg. production/ field (boe/day) Avg. production/ well (boe/day)

1,080 162

Source: Energean Oil & Gas



Country snapshotNorwayOil & Gas royalties and similar taxes

The Norwegian upstream petroleum taxation system includes a special taxon extraordinary profits, as presented in the table below:

Other incentives also include:

no royalties due;

companies that do not have any taxable income may carry forward losses and uplift to subsequent years, with interest;

companies may get a refund from authorities of the tax value of exploration costs for each tax year loss;

deductions are allowed for all relevant costs, including costs associated with exploration, research and development, financing, operations and decommissioning;

consolidation between fields is allowed; This means that losses from one field, or exploration costs, can be written off against the company's income from operations elsewhere on the Norwegian shelf;

to shield normal returns from the special tax, an extra deduction is allowed in the special tax base, called uplift (as shown in the table above).

Production

Type of tax Tax rates

Special petroleum tax 53% / 54% starting with 1st

January 2017, applicable on profits

Royalties None

Uplift for investments 22% / 21.6% starting with 1st

January 2017

730

6,611

Gas

11,674

734

Oil


Production

Reserves

Source: EIA (reserves), Norwegian Petroleum Directorate (production)

0

2,000

4,000

2008

2004

2016

2014

2012

2010

2006

2000

1990

2002

1992

1998

1994

1996


0

2,000

4,000

1996

1994

1998

2000

2002

1990

1992

2016

2010

2014

2012

2008

2006

2004


Oil & gas evolution, (Thousands Barrels per Day)

Source: EIA

Producing fields

No

North Sea 65

Norwegian Sea 17

Barents Sea 2

No of fields Average prod. / field (boe / day)

No of online / operational wells

Average prod. / well (boe / day)

84 offshore only

47,732.40 1,319 3,039.82

Source: Norwegian Petroleum Directorate


Country snapshotHungaryOil & Gas royalties and similar taxes

The rate of mining royalty for exploitation of hydrocarbons depends primarily onthe date of entering the hydrocarbon field affected by exploitation into normalproduction, as well as on the quantity of exploited hydrocarbon from the field.

TypeRoyalties based on production

Before January 1st 2008 Royalties based on production

After January 1st 2008

Oil 16 % of the value generated after the amount of crude oil exploited entered into normal production

12% - if production < 50 k tones/annually

20% - if production between 50 – 200 k tones/annually

30% - if production > 200 k tones/annually

Gas 16 % of the value generated after the amount of natural gas exploited into normal production, from fields entering production between 1998 -2008

royalty rate based on complex formula depending on gas price and adjustments coefficients but minimum 12%, for gas generated from fields enteredinto production before 1998

12% - if production < 300 mnm3/annually

20% - if production between 300 – 500 mn m3/annually

30% - if production > 500 mnm3/annually

The rates of mining royalty (from the table presented on the left) forhydrocarbons are influenced by the world market price of crude oil.Should the monthly average of the stock-exchange listing price forBrent crude oil reaches or exceeds 80 USD/bbl price or 90 USD/bbl,the rate of mining royalty shall rise by 3% or 6%.

8% for natural gas with high inert gas content;

2% royalty for hydrocarbons of non-conventional origin andexploitable with special procedure;

0% for production obtained based on enhanced productiontechniques;

19% minimum royalty in 2014 bidding round;

16% minimum royalty in 2016 and 2017 bidding rounds;


Country snapshotHungary (continued)Production

8

25

11

48

Oil Gas*


Production

Reserves

Source: EIA* Gas production for 2015

0

20

40

60

80

2006

1994

1992

1996

2004

2016

1998

2012

2008

2010

2002

1990

2014

2000


0

50

100

1998

1994

1990

2000

1992

1996

2002

2004

2016

2012

2010

2014

2008

2006



Source: EIA


Country snapshotGermany


Royalties can vary depending on the production and the geographicalposition of the field between a rate ranging from 0% - 40%. The royaltyrates applicable for the main producing fields are presented in the tablebelow:

From a corporate income tax perspective, royalties can be deducted fromthe taxable base.

Incentives Lower Saxony and Schleswig-Holstein:

Royalty payable is reduced due to allowing costs for gathering, processing and transportation of oil and gas, including up to18% general and administrative costs;

Incentives Lower Saxony:

0% royalty for certain fields with difficult conditions (eg. very mature, that requires redevelopment) and small fields;

50% reduction in royalty for redevelopment of abandoned fields/different production horizons;

Production

Type / Location

Schleswig-Holstein

Lower Saxony Bayern

Oil 21% - 40% 0% / 9% / 18% 0%

Gas 18% (producing fields) or 40% (new fields)

7.5% - 30% 5%


Source: EIA (reserves), Authorities report (production)

Source: EIA

Land

Oil Gas

Reserves

Mn. Boe

Yearly productionMn. Boe

Reserves

Mn. boe

Yearly productionMn. Boe


132.515.4

298.251.6

Other lands 1.9 2.9

Incentives Lower Saxony:

Fields with production <4,500 m3 gas/hour: 40% reduction in royalty;

Wells producing from reservoir with <0.6 mD permeability: 75% reduction on royalty for gas for the first 5 years of production;

Oil wells > 4,000 m depth – 50% royalty reduction;

Oil wells using tertiary procedures – 50% royalty reduction.


Country snapshotGermany (continued)

0

50

100

150

2014

2010

2008

2000

1994

2012

1992

1990

1996

2016

2004

2006

2002

1998


0

200

400

600

2014

2012

2010

2006

2004

2002

2000

1996

1994

2016

2008

1998

1992

1990



Source: EIA

Production (continued)

No of fields

Average production /

field (boe/day)No of wells

Average production /

well (boe/day)

TOTAL 127 1,549.1 1,460 134.8


107 1,716.6 1,188 154.6

Other 20 653.4 272 48.0

Source: Authorities report


Country snapshotNetherlandsOil & Gas royalties and similar taxes

The royalty regime is based on the provisions of the licenses by applyingspecific rates to the value of the onshore production*, as follows:

Other similar taxes apply to oil and gas players in the Netherlands directly tothe license holder, such as:

State Profit Share (SPS) at a rate of 50% is imposed against holders /co-holders of a production license on profits that can be directly andindirectly attributed to the extraction of hydrocarbons (the ring fence).The SPS is computed in a manner similar to the corporate income tax, butwith (most) expenses increased by an additional 10%. In order toprevent corporate income tax and SPS from accumulating, a notionallycomputed value (i.e., ‘creditable amount’) can be credited against SPS.

* The royalty for the offshore production of oil and gas is 0%. Royalty ratesincrease by 25% if oil price is higher than $25/bbl and with 100% in absence ofState participation.

Production

Units yearly Gas(mcm)

Oil (th cm)

0 - 199 0% 0%

200 - 599 2% 2%

600 – 1,199 3% 3%

1,200 – 1,999 4% 4%

2,000 – 3,999 5% 5%

4,000 – 7,999 6% 6%

> 8,000 7% 7%0 7

Small fields

183

Groningen

135

Oil & gas production/ year, 2016, Mn boe

Gas

Oil

Source: NLOG

141

Gas

4,786

Oil

Oil & gas reserves/ year, 2016, Mn boe

Source: EIA

• However, a credit with CIT due is applicable and SPS is deductible at the calculation of CIT, which results in an effective SPS rate of ~25% from profits.

• Exploration fully deductible when incurred for SPS

• 25% allowance for SPS for investment in marginal gas fields


Country snapshotNetherlands (continued)Production (continued)

0

50

100

150

1996

1998

1992

1994

1990

2002

2016

2014

2000

2010

2012

2008

2006

2004


200

300

400

500

600

700

2004

2002

2016

2012

2014

2010

2008

2006

1990

2000

1996

1992

1998

1994



Source: EIA

Average production/ day/ well, 2016, Mn boe/ day

0380

154

699

154

Groningen TOTALSmall fields

1,843

Gas OilSource: NLOG

No. of wells OIL GAS TOTAL

TOTAL 107 974 1,081

Groningen - 249 249

Other 107 725 832

No. of fields OIL GAS TOTAL

TOTAL 15 270 285

Groningen - 1 1

Other 15 269 284

Number of wells/ fields with production in 2016

Average production/ day/ field, 2016, Mn boe/ day

01,143

2,609 2,683 2,609

Groningen TOTALSmall fields

501,598

Gas OilSource: NLOG


Country snapshotIrelandOil & Gas royalties and similar taxes

The taxes applicable in the oil and gas sector in Ireland include:

the profit resource rent tax (“PRRT”) applies to licenses granted betweenJanuary 2007 and June 2014, and mainly depends on the profitability ofthe fields, varying between 5% - 15%; it is used in reference to the profitratio achieved on the specific field (cumulative after-tax profits divided bythe cumulative level of capital investment); PRRT is non-deductible forcorporate income tax purposes.

petroleum production tax (“PPT”) applies to exploration licenses afterJune 2014 and is computed based on the net profit of each field; aminimum payment of 5% applied to gross field revenue lesstransportation expenditure is required; PPT is deductible for corporateincome tax purposes; PRRT is not applicable to licences subject to PPTregime.

More information is presented under the below tables:

PRRT

Profit ratio Tax rate

< 1.5 0%

1.5 - 3 5%

3 – 4.5 10%

> 4.5 15%

PPT

R-factor Tax rate

< 1.5 0%

1.5 10%

1.5 – 4.5 Pro-rated

4.5 40%

Exploration and investment costs are 100% deductible when incurred forPRRT and PPT;

25% corporate income tax applies to upstream operations, which ishigher compared to general corporate income tax rate applicable inIreland of 12.5%;

No royalty or supplementary profit tax is applicable to licenses grantedbetween 1987 and 2007;

For licenses granted before 1987 a 12.5% royalty on wellhead basis isapplicable.


Country snapshotIreland (continued)

Production

0.0 0.0

Gas

17.7

Oil

62.3Oil & gas production/ year and reserves, 2016, Mn boe

Gas production in Ireland increased dramatically in 2016 to 2,473 ktoe.This is the highest natural gas production level ever recorded in Ireland.This high level of production from the Corrib field is expected to taper offsignificantly in the next couple of years.

Production

Reserves

Source: EIA, Sustainable Energy Authority of Ireland, Energy

in Ireland Report, 2017

0

1

2

2010

2006

2016

1998

1996

2012

1992

1990

2002

2014

2000

2004

1994

2008

0

50

1996

2008

2006

2014

2012

1990

1994

2002

1992

2000

2010

1998

2004

2016


Source: EIA




967 268

Source: Kinsale Energy website, Integrated Petroleum Affairs System


Country snapshotPolandOil & Gas royalties and similar taxes

The tax regime applicable in the oil and gas sector is based on fixed fee royalties, depending on the gross production:

New regime applicable starting 2016, effective as of 2020: Royalty payable starting 2020: Crude oil offshore and shale oil 3%,

conventional onshore 6%, Natural gas: offshore and unconventional1.5%- conventional onshore 3% . Wells producing in a month lessthan 80 tons of crude oil and respectively less than 1100 MWh areexempt from royalty;

Special hydrocarbon tax payable starting with profits from 2020, whileR-factor starts to be calculated from 2016: tax rate (sliding-scale)depends on the R-Factor, i.e. R<1.5: 0%; 1.5<R<2: 12.5%-25%(linearly); R>2: 25% (obligation to pay this special tax effective fromJanuary 1, 2020);

Exploration and investments fully deductible when incurred for specialhydrocarbon tax.

Production

Type Extraction quantity Royalty fee (PLN)

High-methane natural gas (thousand m3)

> 2,500 24

< 2,500 6.23

Natural gas remaining(thousand m3)

> 2,500 20

< 2,500 5.18

Crude oil(tonnes)

> 1,000 50

< 1,000 36.84

11.7137.7

Oil

513.7

38.7

Gas*


0

20

40

1990

1994

1996

1992

2000

1998

2012

2010

2008

2016

2014

2006

2004

2002


0

100

200

2016

2014

2010

2012

2004

2008

2006

1994

1992

1996

1990

2002

2000

1998

PGNIG is the major oil & gas Company from Poland producing approx. 75%from the total production of Poland for 2016), and is used as a reference forPoland. No of producing wells Poland 2016 operated by PGNIG is ~ 2000.


Production

Reserves

Source: EIA

Source: EIA


608 69

Source: PGNIG Annual Report 2016, PGNIG Corporate Presentation 2017




Country snapshotAlbania


Royalties are computed based on the Petroleum Agreement with Albpetroland include the following:

royalty based on Albpetrol's pre-existing production ("PEP")

gross overriding royalty ("ORR") on new production

royalty tax ("RT") on net production

The rates are as follows:

Additionally profit share is applicable depending on PSA terms.

*In 2016, the PEP royalty rate was of 3%.

Production

Type of tax Royalty / Tax rate

PEP Rate is computed based on the pre-existing production*

ORR 1%

RT 10%

0.25.2

Oil

168.3

8.3

Gas*

Albania has very low natural gas production and remains unconnected toregional gas networks. The Trans-Adriatic Pipeline (TAP), construction of whichis underway and scheduled to finish in 2019, is expected to play a major rolein developing Albania's energy market and facilitating the government'sobjective of becoming a gas hub in the Western Balkans.

Source: EIA *Gas production for 2015


Production

Reserves

0

20

40

2014

1996

2002

2012

1994

1990

2006

2004

2008

1998

2000

1992

2016

2010

0

5

2002

2000

1996

1998

2010

2008

2016

2014

2012

1994

2006

2004

1990

1992




Source: EIA


Country snapshotUnited KingdomOil & Gas royalties and similar taxes

Hydrocarbon tax rate:

• 30% - Ring Fence Corporation Tax (RFCT) – 100% first yearallowances for virtually or capital expenditure;

• 10% - Supplementary Charge (SC) rate - additional charge on acompany’s ring fence profits – reduced rate applicable from 1January 2016;

• 0% - Petroleum Revenue Tax (PRT) applied to fields that wereapproved before 16 March 1993 – reduced rate applicable from 1January 2016;

Main incentives

• 100% R&D allowances for corporation tax and SC purposes, forexploration and appraisal expenditure incurred before a field isconsidered as commercial;

• A company may elect to receive a taxable pre-tax credit of 49% forring-fence companies, or 11% for non – ring fence companies forR&D expenditures incurred on or after 1 April 2013.

• Field allowances apply also for small or new, technically challengingfields (e.g., ultra – heavy oil fields). Starting from 2015, a basin –wide investment allowance, in respect of investment expenditureincurred on or after 1 April 2015 is also applicable at the level of62.5% of qualifying expenditure, for offshore fields, reducing SCbase.

• Onshore allowance of 75% of capital expenditure incurred onprojects after 5 December 2013, reducing SC base.

• Reimbursement of tax value of decommissioning costs.

Production

2,755

1,292

Oil

371 235

Gas


0

1,000

2,000

3,000

1996

2004

1994

2006

2002

1992

1990

2000

1998

2008

2016

2014

2012

2010


0

1,000

2,000

2016

2002

2004

2006

1994

1996

1998

2000

1990

1992

2012

2014

2008

2010


Oil & gas evolution, (Million Barrels per Day)

Production

Reserves

Source: EIA (reserves), Oil and Gas Authority (production)

Source: EIA


5,152.4 479.6

Source: Oil and Gas Authority, Deloitte calculations


Country snapshotDenmark


Nominal hydrocarbon tax (HCT) levied on profits from exploration andextraction of oil and gas – 52% and effective tax rate 39% as corporateincome tax is deductible from HCT base.

Corporate income tax – 25% - applicable for oil and gas companies(reduced to 22% for companies activating in other industries). The 25%should be deducted when computing the hydrocarbon tax, resulting in aneffective tax rate of 64%.

30% uplift for investments performed (5% in a period of six years) – maybe deducted when computing the HCT.

*Not applicable for lease payments, interest, production and administration expenses.

25% uplift per year over a ten year period – may be deducted when computing the HCT, for licenses granted prior to 2014 (applicable under the old hydrocarbon tax regime).

Exploration costs are deductible when incurred or capitalized for tax purposes. If capitalized, such costs benefit of 30% uplift and should be depreciated over a period of 5 years, at an annual 20% depreciation rate, from the year of when oil is firstly obtained.

Tax losses may be carried forward indefinitely, except the hydrocarbon tax losses realized before 2002 which may only be carried forward for 15 years.

In order to encourage the re-development of mature offshore fields were enacted at the end of 2017 the following main incentives, that companies can opt to apply for eligible investments:

increase of uplift to 6.5% per year (39% in total instead of 30%);

depreciation at 20% declining base per year (instead of 15%);

depreciation when costs are incurred instead of commissioning;

If companies opt to apply these incentives and oil price exceeds trigger prices of 75$/bbl and 85$/bbl, the incentives are repaid based on a windfall tax with a rate of 5%/10% applied on profits. These trigger prices are indexed annually with 2%.


Country snapshotDenmark (continued)

Production

371

Oil

235

2,755

1,292

Gas


0

200

400

2016

2014

1990

1994

2000

2006

1992

2012

2008

2002

2010

1998

1996

2004


0

100

200

2016

2014

1992

1990

1994

1996

2008

2006

2002

2012

2010

2000

1998

2004



Production

Reserves

Source: EIA (reserves), Danish Energy Agency (production)

Source: EIA

Avg. production/ field (boe/day)

Avg. production/ well (boe/day)

11,576.9 477.1

Source: Danish Energy Agency, Deloitte calculations

Note: In terms of average production per well, it was calculated considering the total number of production wells as disclosed by the DEA (461 wells, might include also water injection and gas injection wells as split is not available)


Country snapshotAustria


The royalty rates are the following:

Technological upstream gas consumption is exempt from royalty.

Production

Hydrocarbon Rate Calculation base

Liquid 15% < 460 €/ ton

15% - 20% > 460 < 670 €/ ton

20% >670 €/ ton

Gaseous 19% < 5,100 €/ TJ

19% - 22% > 5,100 < 8,200 €/ TJ

22% > 8,200 €/ TJ

6

45

8

50

Oil Gas


0

10

20

30

2016

1994

1998

2012

2002

1990

1996

1992

2010

2000

2006

2008

2004

2014


0

20

40

2014

2010

2008

2006

2016

2012

2004

2000

2002

1998

1996

1992

1990

1994



Production

Reserves

Source: EIA (reserves), Authorities report – Österreichisches Montan-Handbuch 2017 (production)

Source: EIA


226.6 46.8

Source: Authorities report – Österreichisches Montan-Handbuch 2017, Deloitte calculations


Country snapshotItaly


Royalties for oil & gas industry applied generally within a range between 0%and 10%, depending if the concession is on shore or offshore anddepending also on the production level.

A summary of royalties is shown in the table below:

Main incentives - 0% royalty rate applies to production per field notexceeding:

20,000 tons oil and 25 million cubic meters gas / year – offshoreproduction;

50,000 tons and 80 million cubic meters gas / year – onshoreproduction.

Robin Hood Tax - a surcharge tax levied on oil and gas and other energywith revenues exceeding €3 million and a taxable income exceeding€300,000 in the previous tax year, was declared unconstitutional in 2015and abolished.

Local tax on real estate - 0.76% applied to the cadastral value, revalued forcertain multiples established by the law. Starting with 2016, For oil and gascompanies, the cadastral value should be determined net of any movableequipment fixed to them and pipelines.

In 2016, ENI, one of the major industry players from Italy, borne approx.70% from the total amount of royalties on oil & gas paid towards the SpanishState Budget.

Production

Production Royalty rate*

Additional rate Exempted production

Oil Onshore 7% 3% Oil prices reduction

fund

<20,000 tons/year

Offshore 4% 3% Safety and

environmental share

< 50,000 tons/year

Gas Onshore 7% 3% < 25 million cubic meters

Offshore 10% < 80 million cubic meters

*Not applicable for production dispersed, burned or re-injected into a well

337.9

Oil

27.5

Gas

579.2

37.8


Production

Reserves

Source: Directorate-General for Safety of Mining and Energy Activities, Databook 2017 Report – Activity 2016 (production), EIA (reserves)


886 218

Source: Directorate-General for Safety of Mining and Energy Activities, Databook 2017 Report – Activity 2016


Country snapshotItaly (continued)


Indicator Onshore Offshore

Production 2016

Oil 81% 19%

Gas 29% 71%

Total no. of wells

Gas - 656474 344

Oil - 162

No. of exploration licenses

87 24

No. of exploitation licenses

133 69

Source: Directorate-General for Safety of Mining and Energy Activities, Databook 2017 Report – Activity 2016

0

50

100

150

1990

2014

2012

2016

2006

2002

2010

1992

2008

1996

2000

2004

1998

1994


0

100

200

300

400

2008

1998

1994

2000

1996

1992

2012

1990

2004

2006

2016

2002

2014

2010


Source: EIA



Country snapshotSerbia


The applicable fees for mineral resources development are presented in the table below:

Indicative oil & gas royalty and related taxes that can be observed derived from NIS Financial Statements as at December 31, 2016.

Based on the agreement signed between Serbia and Russian Federation, the exploitation fee applicable for NIS is reduced to 3%.

Production

Type Amount/rate Applicability

Exploitation fee 7% Applicable for revenue from sale & use

Concession fee Agreed between the parties

Depending on the type of mineral source, type of activity etc.

7.3

77.5

3.7

303.0

GasOilSource: EIA, Index Mundi


Production

Reserves

0

20

40

2012

2009

2014

2008

2016

2006

2007

2011

2015

2013

2010

0

10

20

2012

2010

2013

2016

2014

2006

2015

2007

2009

2008

2011


No. of oil and gas fields

Avg.production/

field (boe/ day)

No. of exploited oil

wells

No. of exploited oil

wells

Avg. production/

well (boe/day)

50 602 666 78 40.46

Source: Nis Annual Report 2016, Nis website



Source: EIA


Country snapshotFrance


Royalties rates in France cover two components as follows: RCDM - royalties levied on production and not subject to changes in

commodity prices; R31 - royalties computed as percentage of sales.

The level of R31, is presented below:

Crude oil, per annual production (tons):

* Applicable for new productions wells. ** Applicable for wells older than 1980.

Gas, per annual production (million cubic meters)

Production


less 300 0%

more 300 5% (30% for former productions)


Royalty rate –former

productions**

<50,000 0% 8%

50,000 to 100,000 6% 20%

100,000 to 300,000 9% 30%

> 300,000 12% 30%

9.1 0.2

Oil

55.072.0

Gas*


Production

Reserves

Source: EIA

The largest oil producers in France is represented by Vermilion, with a 75% shareof the domestic industry.

0

50

100

2016

1992

2012

2002

1990

2014

2000

1996

2010

1998

2008

2006

2004

1994


0

50

100

2012

2010

2016

2014

1992

1990

2002

1996

2004

1998

2006

2000

2008

1994


Source: EIA




Country snapshotSpain


Royalty rates are computed based on the value of oil, gas and condensatesextracted. The value of the extraction is calculated by applying thereference price approved by the Government (this price is determined bythe average price of the product based on prices in the most representativemarkets), to the total volume of the product extracted.

• Starting with 2016, the royalties rates applicable, depending on annualproduction level and type of exploitation, are the following:

• Corporate income surtax – 5%

• Specific charges for research and extraction activities -1% tax onproduction value payable towards the land owners, where the exploitationtakes place.

Production

Hydrocarbon Volume extractedTax Rate

Onshore Offshore

Oil(barrels)

< 365,000 2% 1%

365,001-3,650,000 6% 5%

> 3,650,000 8% 7%

Gas(m3)

< 32,850,000 3% 1%* 1%

32,850,000-164,250,0000 4% 3%* 3%

> 164,250,000 5% 4%* 4%

*Tax rate applicable for unconventional onshore gas extraction.

1.0 0.3

16.0

150.0

Oil Gas

All of Spain’s main oil fields are situated offshore.

Source: EIA, Cores Statistics


Production

Reserves

0

20

40

2000

1996

2004

1990

2010

2016

1998

2012

2006

2008

1992

2014

2002

1994

0

20

40

1998

1992

1990

2016

2012

2014

2008

2002

1994

2000

2004

2010

2006

1996




No. of Oil fields No. of Gas fieldsAvg. production/ field (boe/day)

5 3 353.69

Source: Cores Statistics

Source: EIA


Country snapshotLithuania


The tax on petroleum and natural gas resources is comprised of the base rate of tax and the compensatory rate of tax on petroleum and natural gas resources.

• Base rates of tax on petroleum and natural gas resources

*20% - applicable for extractions prior to 1 July 2003

• Compensatory tax rate of 9% is applicable for the prospected andexplored areas with State funds.

Starting with 2014, the following tax rates also apply for environmental purposes:

• Tax for conventional hydrocarbons – 12%• Tax for unconventional hydrocarbons - 1% for the first 3 years (until

2020) and 15% thereafter.

Production

Onshore basis (Th.tons/year)

Offshore basis (Th.tons/year)

Tax rate

< 10 < 100 2%

10-25 100-200 4%

25-50 200-300 6%

50-75 300-400 8%

75-100 400-500 10%

100-125 500-600 12%

125-150 600-700 14%

> 150 > 700 16%

0.0 0.0

12.0

Oil Gas

0.7

Source: Tethys Oil Annual Repot 2016, Index Mundi


Production

Reserves

0

5

10

2004

2014

2008

2006

2016

2002

2010

2000

1998

2012

1996

1994

1990

1992



Source: EIA


133 52

Source: Lithuania Geological Survey, European Association of Geoscientists and Engineers


Country snapshotBulgaria


• Royalties are calculated depending on the value of the R-factor. TheR-factor is calculated as the total cumulative revenue excludingconcession fees/ royalties paid reported to the total cumulativecosts, such as exploration, development, appraisal etc. for thereported period.

Production

R-factor Royalty

< 1.50 2.5%

1.50-1.75 5.0%

1.75-2.00 7.5%

2.00-2.50 10%

2.50-3.00 12.5%

> 3.00 25%

*Please note that the royalty rates varies depending on the concession agreement terms per each field

0.4

15.0

0.6

GasOil

35.6

Source: Index Mundi


Production

Reserves

0

2

4

1990

2004

2000

2006

1998

2016

1996

1992

2010

2008

2002

2014

2012

1994

0

2

4

6

8

2012

2008

2006

2004

2002

2000

1998

1992

2016

2014

2010

1994

1990

1996



Source: EIA



Country snapshotCzech Republic


• Royalty rates applicable on revenues obtained from:

Production

Applicability Nominal rate

Extracted reserved mineral for crude oil and natural gas

5%

Crude oil in residual reserves exploited to end (secondary recovery methods)

0.5%

Gas*

24.9

2.1

Oil

15.0

1.6

Source: EIA, Index Mundi


Production

Reserves

0

5

10

15

2016

2014

2012

2010

2008

2004

2002

2006

1996

2000

1992

1994

1998

0

1

2

3

4

5

2014

2016

2006

1996

1994

1992

2002

2000

2004

1998

2008

2012

2010





Producing fields are located in the South Moravian Region in the southeast ofthe country and connected by pipeline to the Kralupy refinery.

Source: EIA



Country snapshotSlovakia & Slovenia

Slovakia


• Royalty nominal rate - 5% on revenue.

Production

Slovenia


• Royalty rate applicable: 1% tax on hydrocarbon extraction

Production

0.1

9.0

0.6

89.0

Gas*OilSource: EIA, Index Mundi


Production

Reserves

0

5

10

2002

1998

2012

2016

1994

2008

2014

2004

2000

1992

1996

2006

2010

0

5

10

2010

2006

2004

1998

1996

2000

2016

2012

2008

2002

2014

1992

1994




0,00

Oil

0,020,00

0,11

GasSource: EIA, Index Mundi


Production

Reserves

0.0

0.5

1998

1992

1996

1994

2002

2000

2014

2016

2012

2008

2010

2006

2004

0.0

0.2

0.4

2000

2002

2014

2016

2012

2010

2008

2006

2004

1992

1996

1998

1994





Source: EIA

Source: EIA


Fiscal regime changes


United Kingdom

Reduction of supplementary charge (“SC”) from 20% to 10% starting with 1st January 2016; Elimination of petroleum revenue tax (“PRT”)** starting with 1st January 2016 (zero rated); The enhanced deduction for research and development expenditure incurred after 1 April 2016 will no longer be available, thus a

company can elect to receive a taxable pre-tax credit of 49% for ring-fence companies, or 11% for non-ring-fence companies, ratherthan the enhanced deduction noted above for R&D expenditure incurred on or after 1 April 2013;

Provide certainty that companies will be able to access tax relief on their decommissioning costs starting with 1 January 2016. Extension from 6 to 10 years of the ring fence expenditure supplement which provides an uplift of 10% on a company’s closing loss

ring fence loss pool at the end of an accounting period. The Onshore Hydraulic Fracturing Regulations were passed on 10th March 2016. Hydraulic fracturing process is allowed only below

1200 meters for the purpose of exploiting oil and gas in specific protected areas. Corporation tax rate for ring-fence companies is currently at 20% and it will be reduced at 19% on 1 April 2017 and then at 17% on

1 April 2020.

Italy

The Robin Hood Tax, levied on oil and gas companies, applicable for excessive profits from high oil prices (companies with revenuesexceeding €3 million and a taxable income exceeding €300,000 in the previous tax year) was declared unconstitutional in 2015 andabolished.

In 2016 the allowance for corporate equity (deduction for CIT purposes) has been fixed at 4.75%; Regarding the local tax on real estate (0.76% of the cadastral value), in 2016 the cadastral value for oil and gas companies is to be

assumed net of any movable equipment fixed to them and pipelines; Starting with 2016, companies may deduct expenses incurred in transactions with enterprises and consultants resident in non-EU tax

havens, without any specific limitation; The budget law 2016 introduces a 40% uplift for tangible assets whose amortization rate for tax purposes exceeds 6.5%.

Poland

Starting with 2016, a new type of tax was introduced, the special hydrocarbon tax ("SHT"), whose taxable base is the surplus ofrevenue generated from hydrocarbon extraction activities divided by the eligible expenditures incurred. However, the obligation topay this special tax is effective from January 2020. Nevertheless, the obligation to keep the appropriate tax records and to filerelevant tax returns came in force as of January 2016.

Amendments to the mineral extraction tax which mainly consists in the modification as regards the extraction value of either naturalgas or crude oil for which, depending on the afore mentioned value, a different value of royalty is payable.

* Given the extensive nature and continuous update, we may not have captured all the changes. These are some of the key changes noted to date. ** Petroleum revenue tax applies to fields developed prior to 1993

Fiscal regime changes effective starting with 2016*


Romania

Abrogation of the special construction tax starting with 1 January 2017. The supplementary tax applied to additional revenues resulted from the deregulation of natural gas prices will be computed by applying

a 60% tax rate, for prices up to 85 lei/ MWh and 80% for the difference between 85 lei / MWh and the realized price. Starting with 2018, the formula used for computing the gas gross extracted production will be based on the average price of the

previous month from Central European Gas Hub (CEGH hub at Baumgarten, Austria). Draft laws are under discussion, differentiating the fiscal regime between the onshore and offshore activities.

Hungary Reduction of royalty from 12% to 2% for non – conventional oil & gas fields and those which requires special exploitation methods; Decrease of minimum royalty in exploration bidding rounds from 2016 and 2017 to 16% compared to 19%.

Norway Increase of special tax rate to 55% from 54% to compensate a decrease of corporate income tax rate of 1% (23% instead of 24%)

starting with 1 January 2018;

Decrease of uplift for investments to 21.2% instead of 21.6% per year starting with 1 January 2018.

Spain

A general restriction to offset losses of 60% of the positive taxable base is set in 2016 (will be 70% starting with 2017), among withother specific restrictions, as follows:

for a turnover ranging from EUR 20 mil. to EUR 60 mil. is limited at 50%; for a turnover exceeding EUR 60 mil. is limited to 25%; in any case, a minimum EUR 1 mil. threshold is set.

Starting with 1 January 2016, royalties rates, between 1% to 8% for oil and 1% to 5% for gas, depending on production level andtype of exploitation, are applicable.

An 1% tax on production value payable to owners of land where exploitation takes place was also introduced.

Starting with 1 January 2016, lump-sum tax of 125k EUR/600k EUR for drilling onshore/offshore wells is introduced.

Denmark

In order to encourage the re-development of mature offshore fields were enacted at the end of 2017 the following main incentives, that companies can opt to apply for eligible investments:

increase of uplift to 6.5% per year (39% in total instead of 30%);

depreciation at 20% declining base per year (instead of 15%);

depreciation when costs are incurred instead of commissioning;

If companies opt to apply these incentives and oil price exceeds trigger prices of 75$/bbl and 85$/bbl, the incentives are repaid based on a windfall tax with a rate of 5%/10% applied on profits. These trigger prices are indexed annually with 2%.

Fiscal regime changes effective starting with 2016*


Limitations and acknowledgements



Methodology:

In compiling information, we have used only publicly available information, as indicated at various places within the analysis andsummarized at the end. To keep objectivity, inference has been kept to minimum, in line with the objective of the analysis to present anoverview. The extent of publicly available information, especially information from the regulators and other relevant bodies, varies fromcountry to country and creates inherent limitation.

Limitations:

The analysis is not a regulatory advice, but an assessment of various other regulatory frameworks. It has limited relevance in terms ofcomparability except highlighting information based on publicly available information that can facilitate a further analysis and debate.

Carrying out such a broad level analysis has inherent limitations due to difference in various countries economic conditions, Oil & Gasindustry history and relevant importance to that country, offshore vs. onshore, gas vs. oil, size and age of the field and inability to capturethe complexities of all variations in different systems.

No detailed discussions with reporting entities or regulatory bodies were carried out to appreciate broad understanding of the publiclyavailable information. Any reader of this analysis must read this report as an indicative analysis and not as a basis for investment decision,understanding project linked Government take analysis or for management decision making.

Deloitte was commissioned by ROPEPCA to perform an overview of the observable effective royalty and similar taxes in Oil & Gas industryacross Europe, in order to have a comparative analysis. Any other party should carry out a thorough analysis for their own needsgathering and using the relevant information.



The reader agrees that Deloitte, its partners and employees neither owe nor accept any duty or responsibility to it, whether by contractor law (including without limitations negligence and breach of any other responsibility), and shall not be liable in respect of any loss,damage or expense whatsoever, which is caused by any use of the reader may choose to make of this report, or which is otherwiseconsequent upon the gaining of access to the report by the reader, the reader agrees that this report cannot be copied or reproduced, inwhole or in part, in any public or legal document or agreement without Deloitte’s prior written consent.

Deloitte in the process of compiling this analysis, has used publicly available data and makes no representation in respect ofindependently auditing this information or verifying the completeness or accuracy of this information.


References and resources



Albania

Bankers Petroleum Ltd - Management's Discussion & Analysis report (for the six months ended June 30 2016)

https://iclg.com/practice-areas/oil-and-gas-regulation/oil-and-gas-regulation-2017/albania

https://uk.practicallaw.thomsonreuters.com/7-628-9666?transitionType=Default&contextData=(sc.Default)&firstPage=true&bhcp=1

Czech Republic

Mineral commodity summaries Czech Republic 2016

Bulgaria

Oil&Gas Exploration and Production PLC Sofia website/ Equipment and Facilities

Petroceltic Annual Report Financial Statements 2016 Petroceltic Aim Readmission Document Subsurface Resources Act

Denmark

Denmark Highlights 2016– Deloitte Danish Energy Agency – Production Oil & Gas in Denmark 2016 Nordsøfonden/Nordsøenheden Annual Report 2016 https://iclg.com/practice-areas/oil-and-gas-laws-and-

regulations/denmark https://thelawreviews.co.uk/edition/the-oil-and-gas-law-review-

edition-4/1140327/denmark Act amending the Hydrocarbon Tax Act, adopted on 28 November

2017 - (Reduction of hydrocarbon taxation for certain investments and abolition of the advance VAT scheme, etc.)

Austria

Federal Mineral Resources Act (Mineralrohstoffgesetz) Mineral Oil Tax Act (Mineralölsteuergesetz) OMV Annual Report 2016 https://uk.practicallaw.thomsonreuters.com

France

Vermilion Energy Annual Report 2016 Vermilion Energy Quarterly Report 2016 https://iclg.com/practice-areas/oil-and-gas-laws-and-

regulations/france

https://iclg.com/practice-areas/oil-and-gas-regulation/oil-and-gas-regulation-2017/albania

https://iclg.com/practice-areas/oil-and-gas-laws-and-regulations/denmark



Germany

Federal Mining Act of 13 August 1980 (Federal Law Gazette I p. 1310), last amended by Article 11 of the Act of 24 May 2016 (Federal Law Gazette I p. 1217)

BASF Annual Report 2016 DEA Annual Report 2016 VDA Jahresbericht 2016 Statistischer Bericht 2016 https://thelawreviews.co.uk/edition/the-oil-and-gas-law-review-

edition-5/1151498/germany https://www.bundesregierung.de/Content/EN/StatischeSeiten/Schw

erpunkte/Nachhaltigkeit/2016-07-08-fracking-gesetz_en.html https://www.gesetze-im-

internet.de/englisch_bbergg/englisch_bbergg.html Ordinance on Field and Subsidy Levies from 22 December 1998 Lower Saxony Regulation on the field - and the mining royalties

Greece

Energean Oil & Gas - Summary of payments to the Greek State 2016

Energean - unlocking the E&P sector in Greece 2017 Oil Regulation – Hydrocarbons Law No. 2289/95 http://www.energean.com/operations/#development http://www.kavalaoil.gr/index.php?act=viewCat&catId=20 http://thelawreviews.co.uk/edition/the-oil-and-gas-law-review-

edition-4/1140330/greece http://www.nortonrosefulbright.com/knowledge/publications/12639

0/oil-and-gas-in-greece http://thelawreviews.co.uk/edition/the-oil-and-gas-law-review-

edition-4/1140330/greece

https://thelawreviews.co.uk/edition/the-oil-and-gas-law-review-edition-5/1151498/germany

https://www.bundesregierung.de/Content/EN/StatischeSeiten/Schwerpunkte/Nachhaltigkeit/2016-07-08-fracking-gesetz_en.html

https://www.gesetze-im-internet.de/englisch_bbergg/englisch_bbergg.html

http://www.kavalaoil.gr/index.php?act=viewCat&catId=20

http://thelawreviews.co.uk/edition/the-oil-and-gas-law-review-edition-4/1140330/greece

http://www.nortonrosefulbright.com/knowledge/publications/126390/oil-and-gas-in-greece



Ireland

Sustainable Energy Authority of Ireland (SEAI) - Ireland's Energy Balance 2016

Sustainable Energy Authority of Ireland (SEAI) annual report 2016 https://www.statista.com/statistics/412806/euro-to-gbp-average-

annual-exchange-rate/ Government of Ireland - Finance Accounts - Audited Financial

Statements of the Exchequer for the Financial Year 1st January 2016 to 31st December 2016

Oil & Gas UK Economic Report 2016 Energy in Ireland 1990-2016 Full Report https://www.irishexaminer.com/business/call-for-oil-and-gas-tax-

terms-to-be-reviewed-445981.html Taxes Consolidation Act, Number 39 of 1997 https://www.dccae.gov.ie/en-ie/natural-resources/topics/Oil-Gas-

Exploration-Production/licensing/Pages/Oil-and-Gas-Tax-Terms.aspx

Hungary

Mining Law: Information on mining royalty Hungarian Energy and Public Utility Regulatory Authority Annual

Report 2016 Hungarian Mining and Geological Office - Mining royalty on

declaration and payment report 2016 MOL - Annual Report 2016 MOL - Investors presentation 2017 MOL - Fact book 2016 https://molgroup.info/en/our-business/exploration-and-production http://www.mbfh.hu/gcpdocs/201506/banyajaradek_mertek_szami

tas_tajekoztato_eng.pdf Government decree No. 54/2008 on the determination of specific

value of mineral resources and geothermal energy as well as the method of valuation

Ministry of National Development presentation - The 4th round hydrocarbon concession tender in Hungary

Official Journal of the European Union (13.6.2017) - Communication from the Minister for National Development of Hungary pursuant to Article 3(2) of Directive 94/22/EC of the European Parliament and of the Council on the conditions for granting and using authorisations for the prospection, exploration and production of hydrocarbons - PUBLIC INVITATION TO TENDER FOR A CONCESSION FOR THE PROSPECTION, EXPLORATION AND PRODUCTION OF HYDROCARBON UNDER CONCESSION IN THE BÉKÉSSÁMSON AREA

Italy

ENI Integrated Annual Report 2016 ENI Fact Book 2016 DGS-UNMIG Directorate-General for Safety of Mining and Energy

Activities, National Mining Office for Hydrocarbons and Georesources: DataBook 2017

https://gettingthedealthrough.com/area/24/jurisdiction/15/oil-regulation-2017-italy/

https://iclg.com/practice-areas/oil-and-gas-regulation/oil-and-gas-regulation-2017/italy

https://www.irishexaminer.com/business/call-for-oil-and-gas-tax-terms-to-be-reviewed-445981.html

https://www.dccae.gov.ie/en-ie/natural-resources/topics/Oil-Gas-Exploration-Production/licensing/Pages/Oil-and-Gas-Tax-Terms.aspx

https://molgroup.info/en/our-business/exploration-and-production

http://www.mbfh.hu/gcpdocs/201506/banyajaradek_mertek_szamitas_tajekoztato_eng.pdf

https://gettingthedealthrough.com/area/24/jurisdiction/15/oil-regulation-2017-italy/

https://iclg.com/practice-areas/oil-and-gas-regulation/oil-and-gas-regulation-2017/italy



Norway

Statoil Annual Report 2016 Petroleum Taxation Act http://www.norskpetroleum.no/en/economy/petroleum-tax/ http://www.norskpetroleum.no/en/economy/governments-

revenues/ http://www.norskpetroleum.no/en/facts/production/

Netherlands

EBN Annual Report 2016 EBN Focus on Dutch Oil and Gas 2016 Mining Act of October 2002, containing rules relating to research

into and extraction of minerals and with regard to mining-related activities

https://www.loyensloeff.com/media/5312/iclg_oil__gas_regulation_2016_11th_edition.pdf

https://www.lexology.com/library/detail.aspx?g=df08cfe1-0abe-4831-8237-0921e9ef6b13

http://www.satprnews.com/2018/01/10/oil-and-gas-industry-in-netherlands/

https://www.export.gov/article?id=Netherlands-Energy https://www.loyensloeff.com/media/5312/iclg_oil__gas_regulation_

2016_11th_edition.pdf

Lithuania

LOTOS Consolidated report payments to government 2016 LOTOS Consolidated Report 2016 LOTOS Presentation of consolidated financial results full year 2016 Law of the Republic of Lithuania on Tax on Petroleum and Natural

Gas Resources

United Kingdom

Oil & Gas UK Economic Report 2017 Oil & Gas UK Business Outlook 2017 Statistics of Government revenues from UK Oil and Gas production

June 2017 Supplementary Table csvs https://www.gov.uk/guidance/oil-gas-and-mining-supplementary-

charge https://www.gov.uk/guidance/oil-gas-and-mining-petroleum-

revenue-tax https://iclg.com/practice-areas/oil-and-gas-regulation/oil-and-gas-

regulation-2017/united-kingdom https://uk.practicallaw.thomsonreuters.com

http://www.norskpetroleum.no/en/economy/petroleum-tax/

http://www.norskpetroleum.no/en/economy/governments-revenues/

http://www.norskpetroleum.no/en/facts/production/


https://www.lexology.com/library/detail.aspx?g=df08cfe1-0abe-4831-8237-0921e9ef6b13

http://www.satprnews.com/2018/01/10/oil-and-gas-industry-in-netherlands/

https://www.export.gov/article?id=Netherlands-Energy


https://www.gov.uk/guidance/oil-gas-and-mining-supplementary-charge

https://www.gov.uk/guidance/oil-gas-and-mining-petroleum-revenue-tax

https://iclg.com/practice-areas/oil-and-gas-regulation/oil-and-gas-regulation-2017/united-kingdom

https://uk.practicallaw.thomsonreuters.com/



Poland

PGNiG - Polish Oil and Gas Company Annual Report 2016 Directors’ Report on the Operations of the PGNiG Group in 2016 Directors’ Report on the Operations of PGNiG S.A. in 2016 Monitor Polski 2016 Consolidated annual report of the PGNiG Group for 2016

Romania

OMV Petrom Annual Report 2016 OMV Petrom Standalone report - payments to the Governments OMV Petrom Separate financial statements 2016 OMV FY/Q4 2016 Preliminary Results and Strategy update ROMGAZ Board of Director’s Report 2016 ROMGAZ Annual Report 2016 Oil Law no. 238/2004 Order of the President of the National Agency for Mineral Resources

on the approval of the Methodology for setting the reference price for natural gases extracted in Romania

Ordinance no. 7/2013 on the introduction of additional revenue taxation obtained as a result of the deregulation of prices in the natural gas sector

OMV Petrom - Capital Markets Story February 2018 Romgaz - Presentation regarding the preliminary results from 2017

published on February 2018 EU energy statistics 2017 http://www.petroleumreview.ro/24-news/1276-ropepca-s-warning-

local-hydrocarbons-production-yields-to-imports http://www.ropepca.ro/articole/noul-cadru-al-redeven-elor-n-

industria-petrolului-i-gazelor-din-rom-nia/518/ http://www.ropepca.ro/articole/fiecare-euro-investit-in-upstream-

onshore-genereaza-un-impact-de-3-2-euro-la-nivelul-intregii-economii-romanesti/318/

http://www.ropepca.ro/articole/ropepca-ii-felicita-pe-toti-petrolistii-romani-de-ziua-lor-si-reaminteste-statului-ca-orice-decizie-politica-si-administrativa-poate-avea-impact-semnificativ-asupra-uneia-dintre-cele-mai-importante-industrii-autohtone/363/

http://www.ropepca.ro/articole/luare-de-pozi-ie-public-cu-referire-la-ordinul-anrm-privind-pretul-de-referinta-la-gazele-naturale/537/

Spain

Repsol Report on Payments to Governments 2016 Repsol Information on oil and gas exploration and production

activities 2016 Repsol Informe Financiero Annual 2016 Law of the Hydrocarbons Sector, which regulates certain tax and

non-tax measures in relation to exploration, research and exploitation of hydrocarbons.

The International Comparative Legal Guide to: Oil and Gas Regulation Spain 2016

https://uk.practicallaw.thomsonreuters.com Law 8/2015, of May 21, which modifies Law 34/1998, of October 7,

of the Hydrocarbons Sector, and which regulates certain tax and non-tax measures in relation to exploration, research and exploitation of hydrocarbons.

http://www.petroleumreview.ro/24-news/1276-ropepca-s-warning-local-hydrocarbons-production-yields-to-imports

http://www.ropepca.ro/articole/noul-cadru-al-redeven-elor-n-industria-petrolului-i-gazelor-din-rom-nia/518/

http://www.ropepca.ro/articole/fiecare-euro-investit-in-upstream-onshore-genereaza-un-impact-de-3-2-euro-la-nivelul-intregii-economii-romanesti/318/

http://www.ropepca.ro/articole/ropepca-ii-felicita-pe-toti-petrolistii-romani-de-ziua-lor-si-reaminteste-statului-ca-orice-decizie-politica-si-administrativa-poate-avea-impact-semnificativ-asupra-uneia-dintre-cele-mai-importante-industrii-autohtone/363/

http://www.ropepca.ro/articole/luare-de-pozi-ie-public-cu-referire-la-ordinul-anrm-privind-pretul-de-referinta-la-gazele-naturale/537/

https://uk.practicallaw.thomsonreuters.com/



Slovenia

Petrol Annual Report 2016 http://www.petrol.si/o-podjetju/petrol/skupina-petrol/geoenergo-

doo https://iclg.com/practice-areas/oil-and-gas-regulation/oil-and-gas-

regulation-2017/slovenia#chaptercontent1

Serbia

NIS Annual Report 2016 https://iclg.com/practice-areas/oil-and-gas-regulation/oil-and-gas-

regulation-2017/serbia#chaptercontent2 https://www.nis.eu/en/about-us/our-business/exploration-

production

http://www.petrol.si/o-podjetju/petrol/skupina-petrol/geoenergo-doo

https://iclg.com/practice-areas/oil-and-gas-regulation/oil-and-gas-regulation-2017/serbia#chaptercontent2


Conversion table

Conversions used across the document

1 boe 0.1589873 cm

1 boe 5.614600 cft

1 boe 0.14 toe

1 boe 0.0017 GWh

1 boe 0.13642565 metric tons

1 cm 6.28981 boe

1 cft 0.17811 boe

1 toe 7.14285 boe

1 GWh 588.24 boe

1 metric ton 7.33 boe

1 PJ 16,3398.69 boe

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Documents

Oil and gas upstream sector across Europe · 2020-03-23 · Oil and gas upstream in Europe”issued in February and September 2015, covering 2013 and 2014, together with our latest