Tullow Oil plc · LSE:TLW
Tullow Oil — Corporate Update (October 2021)
19 slides from Tullow Oil's corporate update, Oct 7, 2021
Slide 1: Tullow Ghana Ltd Supplier Tax Update
Slide 2: Disclaimer
TULLOW Disclaimer Ot This presentation is provided to Tullow Ghana Limited’s (Tullow) Contractors, Sub- Contractors, Consultants and Service Providers (together referred to as “Contractors”) as an overview of the applicable WHT regime following withdrawal of the Cascading WHT Ruling (a private rulin
Slide 3: Overview: Topics for discussion
TULLOW Overview i § Topics for discussion * Stabilised tax regime remains in force at 1s‘ Tier of Contracting (i.e. Tullow Ghana making payments to its Contractors) but the Ghana Revenue Authority (GRA) have expressed conflicting views on how this regime operates to certain Contractors during tax au
Slide 4: Withholding tax (WHT) update
Withholding tax (WHT) update
Slide 5: WHT Regime - Recap on 1st Tier Contracting
TULLOW WHT Regime — Recap on 1% Tier Contracting Ot Overview * A 5% “Final WHT” applies to works/services performed in Ghana by a Subcontractor under contract with Tullow Ghana. Gilow * “Final” means that Subcontractor is not also subject to CIT on this income and cannot claim a credit for the 5% 3%
Slide 6: WHT at 1st Tier: GRA challenging Subcontractors
| WHT at 1° Tier : GRA challenging Subcontractors $27(1) PITL: "Where under the terns of a contract an amount due to a subcontractor in respect of work or services for or in connection with a petroleum agreement the person liable under that contract to make payment to the subcontractor shall withhol
Slide 7: WHT Regime - Recap on Cascading Contracts
TULLOW WHT Regime — Recap on Cascading Contracts Ot Position under Cascading WHT Ruling Position post withdrawal of Cascading WHT Ruling Tullow Tullow Ghana Ghana 5% Final WHT Not subject to WHT 5% Final WHT Not subject to WHT st Tj Ghana JV st Tj Ghana JV 1% Tier [Subcontractor] 1% Tier [Subcontrac
Slide 8: Cascading Ruling - Timing of Withdrawal
TULLOW Cascading Ruling — Timing of Withdrawal Ot * Tullow Ghana received written correspondence from GRA on 11 December 2020 revoking Cascading Ruling and stating withdrawal “should not take retrospective effect”. Tullow cannot share this correspondence with Contractors as content commercially sens
Slide 9: Syndicate Arrangement: Overview
TULLOW Syndicate Arrangement : Overview Ot What is it? * Introduced in 2016 Income Tax Regulations, intention understood to be to bring provisions of cascading ruling (a private ruling issued to Tullow Ghana) into law. * Agreement between a group of Subcontractors (Suppliers) to provide works/servic
Slide 10: Syndicate Arrangement - Example
TULLOW | Syndicate Arrangement - Example Ot Tullow Overview om * Tullow Ghana contracts with Ghana JV Contractor as 5% Final WHT No WHT (unless lead member of a Syndicate of Subcontractors + pbercrmes Grane) * Ghana JV Contractor forms a Syndicate of . r Chama iv | Subcontractors with Resident Subco
Slide 11: Updated contracting strategy
TULLOW Updated contracting strategy ot ° Tullow has revised its Tendering guidelines to give preference to suppliers establishing a tax efficient supply chain and mitigating WHT cost at 2°4 Tier of contracting. ° Tenderers are encouraged to use best efforts to design and implement tax efficient supp
Slide 12: Q&A
Slide 13: Appendix: WHT regime post Cascading Ruling
TULLOW J] L Appendix u Pp WHT regime post Cascading Ruling
Slide 14: Overview
TULLOW Overview Ot * The following analysis represents Tullow’s current understanding of the applicable WHT in Ghana following withdrawal of the Cascading Ruling. ° The stabilised tax regime in Petroleum Agreements and PITL should continue to apply to payments made by Tullow Ghana to its Contractors
Slide 15: Analysis of applicable WHT regime post Cascading Ruling
| Analysis of applicable WHT regime post Cascading Ruling | TYPE OF CONTRACTUAL PAYMENT WHERE PERFORMED WHT TREATMENT LEGISLATIVE BASIS 1st TIER - TULLOW PAYING SUBCONTRACTORS A Works, Services & Rentals specific to Petroleum Operations Resident subcontractor / non-resident subcontractor with Perman
Slide 16: Analysis of applicable WHT regime post Cascading Ruling
TULLOW | Analysis of applicable WHT regime post Cascading Ruling PLIVPE OF CONTRACTUAL PAYMENT = [WHERE PERFORMED | WHTTREATMENT.TLEGISLATIVEGASIS. 1st TIER - TULLOW PAYING SUBCONTRACTORS c Provision of Goods S3 ITA 2015 (Law 896) & Article 12.3 DWT / WCTP PA Resident subcontractors No WHT, subject
Slide 17: Analysis of applicable WHT regime post Cascading Ruling
| Analysis of applicable WHT regime post Cascading Ruling TULLOW | TYPE OF CONTRACTUAL PAYMENT WHERE PERFORMED WHT TREATMENT LEGISLATIVE BASIS 24 TIER - SUBCINTRACTORS PAYING SUB- SUBCONTRACTORS —£ Payment by resident & non-resident subcontractor with PE in Ghana to resident sub-subcontractor Supply
Slide 18: Analysis of applicable WHT regime post Cascading Ruling
Analysis of applicable WHT regime post Cascading Ruling TULLOW | TYPE OF CONTRACTUAL PAYMENT WHERE PERFORMED WHT TREATMENT LEGISLATIVE BASIS 24 TIER - SUBCINTRACTORS PAYING SUB- SUBCONTRACTORS F Payment by resident & non-resident subcontractor with PE in Ghana to non-resident sub-subcontractor Manag
Slide 19: Tullow Ghana Limited
Tullow Ghana Limited 70 George Bush Highway (Motorway Extension) North Dzorwulu Accra Ghana Tel: +233 (0) 302 742200 Fax: + 233 (0) 302 742300 Web: www.tullowoil.com TULLOW J] Follow Tullow on: