The review led by independent expert Michael Callaghan is expected to make its recommendations for any possible changes to make the PRRT "fairer" in April.

 

Woodside, whose CEO Peter Coleman has been trying to win hearts and minds in recent days with opinion columns in newspapers, is keen to press its point that any tinkering with the PRRT regime to increase returns from large-scale LNG via the super profits tax risks future developments.

 

And far from being broken, Coleman argues that the tax is working as expected.

 

Since it produced its North West Shelf gas in 1984, Woodside says it and its partners have delivered billions of dollars in government revenue, primarily from LNG exports and other corporate taxes, and that growth has been facilitated by a tax regime that "recognises it can take some time for investors to recoup the high costs of developing projects in Australia".

 

The oiler's submission argued that it was important to consider the total contribution a project makes to public finances over its lifecycle, rather than just in the early years or at a time of low oil and gas prices when PRRT returns are lower. 

 

Woodside said it had paid $2 billion in PRRT since 2001 alone, while the total taxation burden since the project commenced had seen some $26 billion through royalties and excise paid.

 

"Under the current regime, this contribution is substantial. As an investor, we carry all the burden of project risk, with governments receiving the largest benefit," the submission said. 

 

"For our large, economic gas projects in Australia, taxes account for typically 70% of the total value that the project generates."

 

It said changing the fiscal regime could jeopardise projects and undermine Australia's reputation as an attractive and stable investment destination.

While the company does need more gas resources to keep the North West Shelf fed, Woodside hinted that at a time when it was increasingly looking internationally, local growth and investment could be jeopardised, as it would be harder to justify investing in an expensive jurisdiction like Australia if the PRRT was raised 

 

Despite declining revenues from the PRRT, Woodside said the tax had operated as intended, delivering $200 billion worth of projects over the last decade, although Coleman said last year that should have been probably been closer to $100 billion in developments because of the high costs involved. 

 

"As a profits-based tax, it is not unusual to have declining PRRT at a time of declining oil and gas prices and prior to these projects recouping their costs," Woodside argued.

 

The oiler is particularly concerned by any suggestion of a retrospective tax, warning such moves would undermine those good faith investments previously made for existing projects, reduce the ability to invest in the near term in any expansion plans, and significantly reduce confidence to manage future investments.

 

While there are concerns that some oilers have attempted to minimise tax, such as using transfer pricing, Woodside said it took pride in its contribution to the Australian community, including paying tax.

 

"Woodside does not support the use of artificial structures that have no commercial purpose except the avoidance or minimisation of tax. Our governance arrangements are robust and we are committed to transparency and compliance with the law," Australia's largest pure play oil and gas company said.

 

The likes of Chevron Corporation, ExxonMobil and BHP Billiton have all been accused of profit-shifting on a global scale in recent months.

 

Woodside's tax contribution was called into question last year, but the company said it worked with the Australian Tax Office to ensure everything in its books is in good order, although it would support changes to Australian taxation laws that address specific instances of tax avoidance and increase transparency by taxpayers.

 

The company is considering investments in Browse, Scarborough, and even Greater Sunrise, to add to the $29 billion it has spent over the years in the NWS, Pluto and Wheatstone.

 

"With these three major potential LNG projects in our portfolio, Woodside is materially exposed to any change in PRRT, perhaps more so than any other LNG project participant operating in Australia," Woodside said.

"These projects are already challenging in the current economic climate and any adverse PRRT changes would only stifle continued progress. 

 

"It is critically important that the PRRT Review Team recognise the significant sums from all taxes that these projects stand to deliver to the government."

 

Browse is again in the concept selection phase, recently acquired Scarborough fields are among the most remote gas fields in Australia, while Greater Sunrise is caught in the geopolitical tussle between Australia and Timor Leste.

 

Woodside said any additional costs could easily sink the projects chances of development, and all are 1970s discoveries.

 

The company said that the PRRT was designed to work as part of the overall tax system, and ensure that the Australian people receive significant benefits from income tax receipts from early on in a projects lifecycle, and a substantial share of economic rents earned after the significant capital costs of developing the project have been recovered.

 

"The PRRT is a profits-based tax, so it is unsurprising that tax receipts are lower at a time of low oil and gas prices," Woodside's submission said. 

 

"It was never supposed to apply until the high costs of development had been recovered and is, therefore, not yet payable on some projects.

 

"This should be viewed as strength of the PRRT, rather than a weakness; these arrangements have made investment and development possible, with long-term benefits for Australians."

 

Treasurer Scott Morrison announced the PRRT review in November. 

 

Submissions closed on February 3.