การศึกษาเปรียบเทียบแบ่งผลประโยชน์ผลผลิต จากทรัพยากรปิโตรเลียมระหว่างประเทศ

บทคัดย่อ

1. The Nature of the Problem After world war II, most oil countries have set up National Oil Companies (NOCs) as national instrument to enhance national bargaining power vis a vis International Oil Companies (IOCs) with ultimate goal of reaping maximum return from national petroleum resources. Petroleum resources are valuable but scarce. Investment in it can bring huge benefit but at the cost and risk. Government worldwide have designed optimal fiscal regime to get the maximum benefit from these gas resources with a view to finding the right incentive to private investors. 2. Objective This research report examines comparative international petroleum fiscal system with the objective of learning of experiences of various countries with focus on Asia , Middle East , and Western Hemisphere which utilize either production sharing system or concessionary system regime. 3. Scope of the Report Fiscal petroleum experiences from Asia particularly Indonesia, Malaysia etc which have pioneered production sharing system, from Middle East and selected Western countries such as Australia, Norway, and United Kingdom will be utilized for international comparison. Choices of countries will also be guided by the availability, by comprehensiveness and by the reliability of the data and information. 4. Method of Study The report’s method of study comprise conceptual analysis of the economics of petroleum fiscal regime as well as analysis of secondary data and information pertaining to petroleum taxation of selected countries to be drawn from government and academic sector secondary sources. 5. The Empirical Findings The study finds that ninety percent of countries in the petroleum world adopts the concessionary system and production sharing agreement (PSA), the remaining is service contract predominantly uses in the Middle East. The study found that the fiscal petroleum system in itself doesn’t not tell the superiority of one over another. The strength of bargaining which tend to support the PSA depend on the proven abundance of petroleum reserve, country nationalism and state capacity etc. The above consideration also supports the service contract. However, the study confirms that regardless of the system, the outcome of the fiscal regime depends on the tax design and actual implementation. The study also found that the system is dynamic. Countries’ policy is flexible when environment and competition demand change. This is evidenced since 1970. Countries changed tax method to capture windfall gain from rising oil price. However, there is still room for improvement for the government since the system prior to 2003 is still suboptimal in term of government revenue. Study of total 268 contracts for period 1966-1998 by Bindermann found that contract in Asia is open for negotiation but about 63% of the contract does not require royalty payment. The average 37% cost recovery provision is lowest in the Middle East compared with 66% for Asia. Almost half of the contract stipulated cost recovery level of 40-100% Profit oil for foreign oil company remains relatively lowest for Middle East and highest of 65% in the Central America. Average income tax rate is around 45% which remain quite stable. Cost recovery limit tend to rise in 1990 compared to 1970 period due to increasing competition from new players. Empirical model with different assumption tend to show that in general, the structure, rate of tax and royalty as well as cost recovery limit are important determinant of project profitability and incentive for investor to invest indicative of the fact that fiscal design matters. Kemp et al. found in his research that during the oil price rise in the seventies, government share of revenue differed greatly among countries varying 50-95%. Australia gave the highest return to investor which means also that the government received the lowest share of economic rent. The opposite was found for Malaysia, Egypt getting as high as 90% of economic rent. Dharmadji study also confirmed that Australia granted highest return to investor to be followed by China, India, Malaysia and Indonesia respectively. Putrohari study found that Thailand concessionary system during Thailand I granted the highest return to investor (28.9%) to be followed by Indonesia. Nakhle’s study also found that tax system is very important in determining profitability of oil company in country under study. Various studies by Sunley and Johnston tend to show that regardless of the regime, most countries or 68.75% collected royalty and 78% of developing countries impose corporate income tax but only 25% of the countries use resource rent tax. Only 29 countries stipulated joint state investment requirement. Johnston study found that government receive 70% share in the production sharing system compare with 59% in the concessionary system. Johnston also found that 87% of economic rent collected by the state came from royalty and profit variable. 6. Suggested Recommendation There are a number of important lessons that Thailand should learn from these findings. The system must be dynamic in recognition of the change so that Thailand can remain competitive with due consideration to Thailand strength and weakness. Thailand need to find the right balance between getting the most in economic rent from petroleum resource and attracting foreign oil company to invest using modern technology and producing with lowest cost. The government should be aware that ultimately the market and competition will determine the share that the government should receive from petroleum resources. The government should also give high consideration to efficient utilization of government revenue for the benefit of future generation.

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