Matt Kean demanding WA provide gas at a discounted price to the east coast., page-48

I'm, with ya MM, but how else can the tax paid claim make sense?

• Special income tax and PRRT treatment applies to expenditure incurred on 'exploration'. The boundaries of what constitutes 'exploration' have long been the subject of considerable debate between taxpayers and the Commissioner.
• The Commissioner has previously sought to limit 'exploration' to mere discovery, such that 'exploration' ceases at the point where the taxpayer has obtained sufficient information to know that a resource exists, which industry did not accept.
• The recent Shell decisions, in which Allens acted for Shell, dealt with the meaning of 'exploration' in the context of the Petroleum Legislation and former section 40-80, rather than the meaning of exploration under other provisions of the Income Tax Assessment Act 1997 (Cth) (Income Tax Act) or under the Petroleum Resource Rent Tax Assessment Act 1987 (Cth) (PRRT Act). However, the Shell decisions addressed the ordinary meaning of 'exploration', which is the starting point for determining whether expenditure will qualify for exploration relief under those laws. Therefore, the Shell decisions will now guide the meaning of exploration for income tax and PRRT.

https://www.allens.com.au/insights-news/insights/2022/09/shell-energy-holdings-v-commissioner-of-taxation/

Raider