Woodside Energy Ltd v Commissioner of Taxation (Corrigendum dated 13 February 2009)

[2009] FCAFC 12

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Interrogate

Catchwords

1. Taxation
2. › Petroleum resource rent tax
3. › Assessable petroleum receipts
4. › Consideration receivable less expenses payable in relation to sale
5. › Whether losses from hedging contracts are expenses payable in relation to sale of project produce
6. › Whether hedging gains or losses constitute consideration receivable
7. › Petroleum Resource Rent Tax Assessment Act 1987 (Cth), s 24(b)
1. Statutes
2. › Interpretation
3. › Purposive construction
4. › Contextual interpretation
5. › Whether purposive construction warrants extending statutory language to unenvisaged circumstances
6. › Limits of purposive construction
7. › Acts Interpretation Act 1901 (Cth), s 15AA

Quick Take

Petroleum resource rent taxpayers cannot deduct hedging losses as expenses payable in relation to the sale of petroleum under s 24(b) of the PRRTAA; hedging gains and losses fall outside the PRRT framework but may be brought into account for income tax purposes.