The Influence of Additional Profits Tax on Mining Strategies on Papua New Guinea

Resource rent tax is a form of taxation or royalty, which only become effective at such a time as a pre-determined rate of return has been achieved by an operation. The offshore petroleum industry in Australia is already subject to RRT as is the Roxby Downs (Olympic Dam) Mine in South Australia. Both the mining and petroleum taxation regimes in Papua New Guinea include a resource rent tax component called Additional Profits Tax (APT). The implications of the current form of Additional Profits Tax for shareholder cash returns are that the tax burden on the operation may suddenly increase at some stage in the life of the mine, if and when the threshold level of profitability for the tax to be triggered is exceeded. From that point in time onwards the cash return to the shareholders on the capital invested is greatly diminished. For mining companies in Papua New Guinea, the effective tax rate increases from 35% to 57.75% as a result of the onset of Additional Profits Tax. This tax rate penalty is so severe that there appears to be merit in considering the concept of managing profitability through time rather than purely maximising annual pre-tax profits as is currently the case in most mining operations. This would have the benefit of deferring or perhaps preventing altogether the onset of the tax. One possible method for the effective management of profitability is through the control of average mining grade by cutoff grade manipulation. Traditional cutoff grade theory has usually considered taxation as a direct cost at a fixed or variable percentage of annual profits. As a result of this most analyses are conducted on a pre-tax basis. If tax is included in analyses it is usually present as a time independent function of gross profit. Additional Profits Tax is both time and rate of return dependent and therefore not adequately accommodated by currently accepted cutoff grade theory. A review has been made of the effects of resource rent taxes on both the investment decision-making process as well as possible development and mining strategies which may be employed by mining companies faced with Additional Profits Tax. The review includes examples based on the structure of Additional Profits Tax which is levied in Papua New Guinea.