Petroleum tax and financial decisions

The work presented in this report focuses on tax motivated financial incentives in the Norwegian petroleum tax system. Of particular concern is the effects of the reserve fund requirement in the Joint Stock Companies Act. Our prime concern is the Norwegian petroleum tax system as applicable from January 1992, but for the sake of comparison, we have also examined the ''old'' Norwegian petroleum tax system. The findings presented in this report can be divided in two parts. Based on an overview over the development in debt and equity for the major part of companies operating on the Norwegian continental shelf it seems reasonable to divide the companies in three groups. The first group is companies which is not in a tax paying position, both ''foreign'' and domestic. These companies seem to use debt as their most important capital source. The second group is Norwegian companies in a tax paying position. These companies also seem to use debt as the most important capital source. The last group is ''foreign'' companies in a tax paying position. This is a group of companies that mainly use equity to finance their investments in the offshore sector. The second part of the report tries to explain these observations. In the report we compare the incentive effects in the new petroleum tax system to the old tax system. The incentives to finance investments with debt is stronger in the new tax system. Several explanations emerge. Firstly, in the old tax system the investor got an effective tax deduction of 12.8% for dividends. This is removed in the new system. Secondly, in the new system 78% tax is included in the financial statements after tax profit calculation and the maximum dividend calculation, while in the old tax system the withholding tax was excluded. 31 refs., 13 figs. 2 tabs