LEGAL AND TAXATION ASPECTS OF FARM-INS AND FARM-OUTS OVER EXPLORATION TENEMENTS

Abstract

The paper considers the basic capital gains tax implication arising out of farm-outs and how to structure those farm-outs in the light of up-front payments and disproportionate funding. In particular, consideration is given to the acquisition and disposal dates and how altering those dates will impact on the asset cost base of the farmor/farmee. The problem of determining value is also considered.