Tuesday, August 2, 2016

Malampaya tax claims swell to P130.34 B



by Myrna Velasco July 26, 2016

The income tax amount being pursued by the Philippine government, through the Commission on Audit (COA), against the Malampaya consortium has already swelled to a whopping P130.34 billion.
According to Department of Energy (DOE) Spokesperson Wimpy Fuentebella, the additional amount lodged, based on COA documents, had been R77.2 billion.
It was further gathered from sources at the State audit agency that the amount had been on top of the initial P53.14 billion being demanded prior to the filing of an arbitration case by the Service Contract 38 consortium before the International Center for Settlement of Investment Disputes (ICSID).
The additional P77.2 billion had just been reckoned from years 2010 to 2014 operation of the Malampaya gas field. The SC 38 consortium comprises of Shell Philippines Exploration B.V. (SPEX), Chevron Malampaya LLC and state-owned Philippine National Oil Company-Exploration Corporation.
In regard to the international arbitration, Fuentebella explained that the ‘conclusion’ of the government “is to have a unified stand between and among all the agencies concerned on how to approach the proceedings.”
He added that the COA and Department of Finance (DOF) have respective positions on the matter – generally to go after the claimed income tax components and for it not to be integrated in the 60-percent royalty share of the Philippine government in the Malampaya gas field project.
The DOE, for its part, has to be cautious on the chilling effect of such process on future investment prospects in the upstream segment of the country’s oil and gas sector.
“DOF has its own stand, and also independent COA… us at the DOE, we also have our stand. If the issues and discussions are just confined in the Philippines, we would just have performed our different mandates under the law because we have checks and balances in our system… but when you bring it to international arbitration, then we should have a unified stand,” he stressed.
Fuentebella expounded that the next step will be for all different concerned agencies to ‘sit down and discuss’ whatever common stand and legal strategy the Philippines must take in the arbitration case. The case was also referred to President Rodrigo Duterte for his guidance.
The energy department, Fuentebella said though, is still hopeful that the parties could arrive at “win-win” settlement at the arbitration proceedings.
On the part of the Malampaya developers, they have been strongly invoking “sanctity of contracts;” and that such must be upheld by the government as this is also sanctioned by the Philippine Constitution.
On this, Fuentebella noted “we can also invoke that (sanctity of contracts), but the problem is how do you interpret the terms of the contract?”
Relative to the arbitration case, it was noted that the Philippine government has challenged the jurisdiction of the ICC tribunal. Hearings are slated November this year.

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