Maya Forstater

Citing cases: Interest - Chevron v ATO, Marketing hub - BHP v ATO, Capital Gains Tax - Heritage Oil v URA and Alleged underpricing of mineral sales Cameco v CRA (going to appeal)

. @ali_readhead argues that tax avoidance is "the missing principle of extractive industry fiscal design" -- other principles taken into account: revenue raising potential, neutrality stability, timing, administration, investor & government risk

The operating budget of Sierra Leone's revenue authority is $13m ..... 1% of Australia's and just a little bit more than the cost to the ATO of bringing the case against Chevron. (NB: Sierra Leone GDP is about 0.3% of Australia)

"FARI - the IMF's tool for modelling natural resource revenues does not take into account tax avoidance and tax planning" https://www.imf.org/external/np/fad/fari/ …

Ali: we need a include vulnerability to tax abuse as a standalone principle for thinking about fiscal design.

Factors to consider: Production sharing agreements are less liable to tax avoidance? Or is it the fact of Joint ventures (an internal policing mechanism) ? Carried equity raises the risk

When modelling fiscal regime should take into account behavioural responses to incentives. E.g. its not just the direct WHT but profit shifting via increased interest payments. Take account of other country's experience -- projected vs actual revenues. Avoid optimism bias