UK - best O&G tax regime in the world25 Jan 2024 20:56
Feeling like the defence lawyer at Fred West’s trial, but give me a moment to explain.
Yes, we have moved from an incredibly generous tax system whereby O&G operators kept 60% of profit, but equally had to fund approx 60% of capital costs of development. Yes, because of the EPL, the value of existing 2P reserves have halved from $20 per barrel to $8-10 per barrel and 2C pretty much worthless. This has destroyed the market value of listed groups and has effectively nationalised 75% of 2P reserves which were funded by the private sector.
So yes the EPL has decimated the value of existing reserves and has clearly left more than a bitter taste for operators and investors. However, putting aside the emotional and financial impact on past values (very hard to do I admitted) and looking objectively as to the attractiveness of new investment, the picture looks very different.
Let me explain - and this only applies to companies like Harbour paying full 75% tax.
Let me use the example of a new field of 40m barrels which costs $15 per barrel CAPEX to develop ($600m - similar cost per barrel to Rosebank) and $18 per barrel OPEX. The net CAPEX cost to the operator is $54m after 91% allowance.
Production 3m barrels per year over 13 years. Oil price $78 per barrel and FCF pre tax $60 per barrel and post tax $15 per barrel or $45m per year post tax FCF.
So under the current regime, net CAPEX per barrel is $1.8 per 2P reserve and FCF $15 per barrel resulting in annual $45m return from a $60m investment - payback 1 year and 4 months. I am not aware of any other tax regime that derisks O&G projects to this degree and provides such rapid payback for new investments.
However this is contingent on the current investment allowance remaining. What is the financial impact of Labour removing the additional allowance uplift (reducing the allowance from 91% to 75%)? The result is net CAPEX increases from $54m to $150m ($5 per barrel of 2P reserves) and FCF payback extends to 3 years and 4 months - no where near as attractive.
Accordingly it is understandable why there has been some hesitancy into committing to post 2024 investments until Labour shows it colours. The real unfairness of the EPL is that it does not allow past losses to be offset and interest on debt, which funded historical capex, to be offset.
We have to accept that unless the tax regime dramatically changes (and I think it will pre 2028) that we are effectively an operator of Nationalised assets, where the State funds 91% of capital costs and allows the operator to keep 25% of pre CAPEX FCF. Not a bad deal if you ignore the transition. Norway only funds 78% of CAPEX (72% in year 1 and 2% a year for 3 years) and allows the operator to keep 22% of pre CAPEX FCF.
I rest my case after applying for Police protection