ABSTRACT
This chapter proposes a new system for the UK's petroleum tax regime that takes the guiding principles of the Fiscal Review to their natural conclusion. In order to reach that natural conclusion the proposal first envisages a single-pillared tax regime. Retrospective application is undesirable because it would increase the fiscal instability for which the investors would attach a higher risk premium, thus requiring a higher return for investing into the United Kingdom continental shelf. The simplest form of resource rent tax, at least theoretically, was posited in 1948 by E. C. Brown and referred to either as Brown Tax, R-based cash-flow tax or as pure rent tax. The Australian government announced in its 2010–2011 Budget its proposal for introducing Resource Super Profits Tax applicable to upstream resource extraction projects from 1 July 2012. This was in response to the report by the then Secretary to the Treasury, Dr. Ken Henry presenting 138 recommendations to the overall Australian tax system.
