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The international taxation of oil, gas, and the energy transition — including fiscal regimes, ring-fencing, production sharing contracts, and carbon pricing.
Formerly known as "Upstream Oil & Gas", this module is the most strategically relevant ADIT paper for West Africa — particularly Ghana, Nigeria, and the broader Sub-Saharan oil and gas corridor.
This is an optional module and can be taken standalone for a certificate.
Ghana is an oil-producing and mining-intensive economy. This module directly applies to Ghana's Petroleum Income Tax Law (PITL), Production Sharing Agreements (PSAs), ring-fencing rules, and the mining fiscal regime. No other ADIT provider in Ghana is offering this paper. This is a monopoly position.
| 1 | Introduction to Energy Taxation — why oil/gas is taxed differently |
| 2 | Fiscal Regimes — concession systems, PSCs, service contracts |
| 3 | Ring-fence Taxation — concept, purpose, application |
| 4 | Royalties — calculation, gross vs. net, sliding scales |
| 5 | Special Petroleum Taxes and windfall profit taxes |
| 6 | Government Take — measuring fiscal regime competitiveness |
| 7 | Permanent Establishments in oil and gas — service companies |
| 8 | Transfer Pricing in oil and gas — commodity transactions |
| 9 | Taxation of Intellectual Property in energy sector |
| 10 | Mergers, Acquisitions and Farm-outs in oil and gas |
| 11 | Financing structures — intercompany loans, thin capitalisation |
| 12 | Withholding taxes in energy context |
| 13 | CFC rules and hybrid instruments in energy groups |
| 14 | Carbon Pricing — emissions trading schemes, carbon taxes |
| 15 | Energy Transition — tax treatment of renewables |
| 16 | Country Examples — Nigeria, Ghana, UK North Sea |
| 17 | BEPS impact on oil and gas multinationals |
Prof. Bill Cobby Impriam
"No other tuition provider in Ghana offers ADIT Energy Resources. With Ghana's oil, gas, and mining sectors growing, this is the highest-value ADIT paper you can hold in this region."