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Asset unitisation paper


This paper covers:

  • the fiscal environment
  • alternate approaches to structuring unitisations
  • direct asset unitisation involving UJV
  • direct asset unitisation involving a partnership
  • incorporated unitisation
  • synthetic asset unitisation.

Author profiles

James O'Reilly
James is PwC Australia's Tax Leader for Energy & Mining. He is based in Brisbane and specialises in advising clients investing in the Australian resources industry, with a particular focus on the coal, oil & gas and precious metal industries. James has extensive knowledge of the tax issues relevant to resource operations, including the tax implications associated with the various stages of a mining operations' life cycle (i.e. exploration, development, operation and cessation), the establishment of joint venture arrangements, M&A activity and the application of State based royalty regimes. Part of James' focus is advising inbound multinationals on their Australian investments, including advising on the tax implications associated with alternate structures for inbound investment and financing. - Current at 04 October 2017
Janelle O'Hare
Janelle is the Head of Tax at Santos and is based in Adelaide. Janelle joined Santos from PwC where she was a partner in the corporate tax team in Perth, leading that national energy and resources practice for tax. She has over 21 years of tax advisory experience, specialising in oil and gas. - Current at 01 April 2022
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Jess Fantin
Jess Fantin is a Director in the Brisbane Stamp Duty and Land Tax Team at PwC and has over 9 years specialist experience advising clients with existing agriculture operations and those wanting to invest in Australian agriculture. Most recently, Jess played a key stamp duty advisory role in respect of PSPIB’s acquisition of ASX listed Webster Limited. She also worked closely with several agribusiness clients, Agforce and the Property Council during the 12 month consultation process for the QLD foreign land tax surcharge ex gratia guidelines and has assisted a number of clients with applying for ex gratia since the guidelines were introduced. Jess’ passion for working with agribusiness and assisting clients stems from her background growing up on a sugar cane farm south of Cairns, which she now owns with her 2 siblings. - Current at 15 April 2021
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This was presented at 2018 National Resources Tax Conference .

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The R&D tax incentive - The shifting policy & regulatory landscape

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