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Australian Energy Producers Journal Australian Energy Producers Journal Society
Journal of Australian Energy Producers
RESEARCH ARTICLE

The tax profile of different models of infrastructure asset ownership and funding

Michael Chang
+ Author Affiliations
- Author Affiliations

Ernst & Young, Level 51, 111 Eagle Street, Brisbane, Queensland 4000, Australia. Email: michael.chang@au.ey.com

The APPEA Journal 59(1) 47-57 https://doi.org/10.1071/AJ18196
Submitted: 7 January 2019  Accepted: 25 March 2019   Published: 17 June 2019

Abstract

There are several significant capital and infrastructure projects currently being undertaken in the oil and gas sector. This article will explore the tax issues associated with different models of infrastructure asset ownership and funding. This article will also discuss the tax profile of different investment vehicles, including the impact of recent legislative changes to the taxation of stapled structures and managed investment trusts.

Keywords: asset funding, depreciation, income tax, lease, managed investment trusts, stapled structures, tax, tax profile

Michael Chang is a Partner with Ernst & Young, Brisbane, with 19 years’ experience. During his career he has worked in various areas of corporate and international taxation in Australia. Michael’s main focus is in taxation issues associated with large transactions (mergers and acquisitions (M&A) and infrastructure transactions). Michael’s work focuses on oil and gas clients, and he has worked with several onshore and offshore projects as well as several recent large scale oil and gas M&A transactions.


References

Ernst & Young (2018). Australia introduces Bill for stapled structures, non-concessional MIT and other foreign investor changes, Ernst & Young, September 2018. Available at: https://www.ey.com/gl/en/services/tax/international-tax/alert--australia-introduces-bill-for-stapled-structures--non-concessional-mit-and-other-foreign-investor-changes [verified 26 March 2019]