NAPIMS - Fiscal Regime & Incentives

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Land	Swamp/Shallow Waters	Shallow Offshore	Deep Offshore
Onshore ? 20%	0 ? 100m: 18.5%	100 ? 200m: 16.67%	201 ? 500m: 12%
			501 ? 800m: 8%
			801 ? 1000m: 4%
			Over 1000m: 0%

• As contained in the Memorandum of Understanding (MOU) for JV

• Upstream Gas Utilization:

Capital allowance: 20% per year (year 1 ? 4) and 19% in year 5

Petroleum Investment Allowance (PIA): 10% as for oil.

Income tax is based on CITA (30%) where expenses are identified as

exclusively for gas.

Custom Duty: 2.5% (Government Circular of 2002)

• All capital investment relating the gas-to-liquids facilities shall be

treated as chargeable capital allowance and recoverable against oil income.

Gas transferred from the natural gas liquid facility to the gas-to-liquid facility shall be at zero percent tax and zero percent

All incentives granted in respect investment in associated gas shall be applicable to non-associated gas.

Condensate extracted and re-injected into the crude oil stream shall be treated as oil but those not re-injected shall be

Downstream Gas Utilization.

Capital Allowance: 90% in the first year of production and 10% retained in the books.

Petroleum Investment Allowance (PIA): 35% (if no tax holiday is exercised or 15% (if tax holiday is exercised).

Tax Free Period: 3 yrs in the first instance, and renewable for additional two (2) years subject to satisfactory performance. The tax-free period

shall start on the day the Company commences production as certified by the Ministry of Petroleum Resources.

Tax free dividend during the tax-free period.

Zero % VAT for plants, machinery and equipment

Custom duty: 2.5% (Government circular of 2002)

Interest on loan: Deductible provided there is prior approval of FMF.