This is Australia · 1984–2026

Australia’s
Gas Tax Story

From resource rent to royalty-free exports: how a tax created in the Hawke–Keating era became the centre of a forty-year argument over who benefits from Australia’s gas.

Begin the story

The original deal: 1984

Encourage exploration and investment,
share the super profits with Australia.

Australia already has a gas tax. The problem is that its structure can delay payment for decades.

In 1984, the government under Prime Minister Bob Hawke and Treasurer Paul Keating proposed a new way to tax Australia’s offshore oil and gas.

The idea was simple. Companies would be encouraged to spend billions of dollars searching for oil and gas and building new projects. If a project failed or made only a modest profit, it would pay little or no special tax. But if it became highly profitable, Australians would receive a share of those super profits.

The Petroleum Resource Rent Tax—or PRRT—was passed in 1987 and began operating in 1988. The tax rate was set at 40% of a project’s profits. But companies did not pay 40% of everything they earned. They could first subtract the money spent finding, developing and operating each project.

If those costs were greater than the project’s income, the unused amount could be carried into the following year. Then came the crucial rule: uplift.

Uplift allowed some of those unused costs to grow every year. It was meant to compensate companies for investing their money and taking the risk that a project might fail.

But uplift is not money the company actually spent. It is an extra deduction created by the tax system. And because it compounds, it can grow quickly.

For example, a $100 million deduction growing at 10% becomes $110 million after one year, $121 million after two years and more than $259 million after ten years.

This growing amount can then be used to reduce the profit calculated for the gas tax. That means a project can be producing gas, earning billions of dollars and making a profit in the ordinary business sense—but still show no profit under the PRRT calculation.

No PRRT profit means no 40% PRRT bill for that year.

Money collected from Australia’s natural resources could have helped fund hospitals, education, infrastructure or long-term savings for future generations. Other resource-rich countries, including Norway, collected and invested far greater public returns from their oil and gas. Australia chose a different path.

Over the following four decades, Australia became one of the world’s largest exporters of liquefied natural gas. Unfortunately, the tax system did not change at the same pace.

The tax exists. The deductions can outrun it. That does not mean every gas project pays nothing or that gas companies pay no other taxes. It means the 40% gas tax can collect little or nothing from a project until its accumulated deductions are finally used up.

40%Headline tax rate on taxable project profit
1989–90First Commonwealth PRRT receipts
90%Maximum deductions against covered LNG assessable receipts from July 2023
4%Resulting floor on assessable PRRT receipts—not gross export sales

The 60-second history

How Australia locked in today’s LNG reality

Australia’s present position was not created by one government or one contract. It developed through forty years of tax design, project approvals, export investment and partial reform.

  1. 1984–1988

    A profits tax is created

    The Hawke government develops PRRT as a tax on exceptional petroleum-project profits. Projects recover eligible expenditure first, with some unused deductions uplifted while carried forward.

  2. 1989–2006

    Australia enters the LNG era

    North West Shelf ships its first LNG cargo in 1989 under royalty and excise arrangements rather than PRRT. Western Australia adopts a domestic-gas reservation policy in 2006.

  3. 2009–2012

    The megaproject wave is locked in

    Gorgon, Queensland’s three coal-seam-gas LNG ventures and Ichthys reach final investment decisions, supported by long-term Asian sales contracts and government approvals.

  4. 2012

    PRRT expands onshore

    The Gillard government extends PRRT to onshore petroleum and North West Shelf. Starting-base rules recognise existing investment, adding substantial deductions before the expanded tax can bite.

  5. 2017–2019

    Reviews expose the delay

    The Callaghan Review identifies large carried-forward deductions and delayed LNG receipts. The Morrison government narrows future uplift treatment and removes onshore projects from PRRT in 2019.

  6. 2023 onward

    A partial floor arrives

    The Albanese government caps deductions used by covered offshore LNG projects at 90% of assessable receipts. It brings some revenue forward but does not erase accumulated deductions.

Important date: QCLNG produced LNG in December 2014; its first commercial cargo departed in January 2015. The distinction matters when comparing construction, production and export timelines.

Responsibility, not a rollcall

Who made the key decisions?

Holding office is not the same as making a decision. These are the governments and portfolios connected to identifiable changes in the tax or gas-policy framework.

1984–1988 · Hawke government

PRRT conceived and legislated

Treasury and resources portfolios developed a project-based rent tax under Prime Minister Bob Hawke and Treasurer Paul Keating. The legislation commenced on 15 January 1988.

Decision: tax calculated project profit rather than each unit produced.
1990–1991 · Hawke government

Bass Strait and transferable exploration

Bass Strait entered PRRT. Qualifying exploration deductions became transferable within eligible company groups, while general and exploration expenditure received different uplift treatment.

Decision: broaden the regime while retaining generous risk compensation.
2009–2012 · Rudd and Gillard governments

LNG investment encouraged

Federal and state governments approved and promoted a wave of capital-intensive LNG projects. Project companies—not ministers—negotiated the commercial LNG sales contracts.

Decision: prioritise investment, construction and export capacity.
2012 · Gillard government

PRRT extended nationwide

Prime Minister Julia Gillard’s government, with Treasurer Wayne Swan and Resources Minister Martin Ferguson, extended PRRT to onshore petroleum and North West Shelf.

Decision: expand coverage while recognising existing project investment through starting bases.
2019 · Morrison government

Future uplift narrowed; onshore removed

Following the Callaghan Review, the government reduced uplift treatment for future expenditure and removed onshore petroleum projects from PRRT. Legacy deductions were not cancelled.

Decision: reform prospective rules without retrospectively rewriting old pools.
2023–2024 · Albanese government

The LNG deductions cap

Prime Minister Anthony Albanese’s government, led on tax by Treasurer Jim Chalmers, legislated the 90% cap for covered offshore LNG projects.

Decision: force some PRRT to be paid sooner while leaving unused deductions available later.

A tax that kept changing shape

How PRRT expanded—and then contracted

PRRT did not begin as a nationwide gas tax. Its geographic reach, deduction rules and affected projects changed repeatedly.

  1. 1988

    Selected offshore petroleum

    PRRT begins for specified offshore projects outside the established royalty regime.

  2. 1990–91

    Bass Strait and new deduction rules

    Bass Strait enters. Exploration transfers and separate uplift classes reshape the system.

  3. 2012

    Offshore and onshore expansion

    PRRT extends to North West Shelf, coal-seam gas, shale gas and other onshore petroleum projects.

  4. 2019

    Onshore projects removed

    PRRT returns principally to offshore petroleum. Future uplift rules are narrowed, but accumulated legacy deductions remain.

  5. 2023

    Covered LNG deductions capped

    Relevant offshore LNG projects can generally use deductions against no more than 90% of assessable receipts in a year.

Plain answers

Questions Australians reasonably ask

The argument becomes confusing when company tax, royalties, export revenue, PRRT and accounting profit are treated as if they are the same thing. They are not.

01Who owns Australia’s gas before it is extracted?

Petroleum resources are administered by Australian governments on behalf of the public. Companies receive exploration and production rights under legislation; owning a company or an LNG plant does not mean the company originally owned the gas underground.

The public-policy question is what Australians receive when a finite resource is depleted and sold.

02Is the industry correct when it says it pays billions in tax?

The industry can legitimately count company tax, payroll tax and other payments in its economic contribution. But company tax is the ordinary tax expected of profitable businesses. It is not, by itself, a specific payment for acquiring a publicly owned raw material.

Royalties, excise and PRRT answer a different question: what additional return does the public receive for extraction of the petroleum resource?

03Why are PRRT receipts only around $1.4–$1.5 billion?

PRRT is not charged directly on export sales. It applies at 40% to a project’s taxable PRRT profit after eligible deductions. Large development expenditure, transferred exploration deductions, starting bases and uplifted unused deductions can postpone taxable profit.

The latest actual result in the chart below is $1.420 billion for 2024–25. The $1.4 billion figure for 2025–26 is a Budget estimate.

04How does Australian gas become LNG export income?

Gas is discovered, appraised, developed and transported to a processing facility. Water and impurities are removed, the gas is chilled into LNG, loaded onto ships and sold under long-term contracts or into spot markets.

Japan, China, Korea and other customers may sign contracts lasting decades. Export revenue must cover production, transport, liquefaction, financing and marketing before accounting profit or PRRT profit is calculated.

05What is uplift—and is it a tax credit?

Uplift is annual growth applied to specified unused PRRT deductions. It is not a refundable tax credit and the government does not hand the company cash. Instead, the available deduction becomes larger while carried forward.

Because the growth compounds, old expenditure can become substantially larger before it is used. Rates and time limits differ by expenditure class and when the spending occurred.

06Can a commercially profitable company still pay no PRRT?

Yes. Company accounting profit and PRRT taxable profit are calculated differently. A company can report profit to shareholders while a petroleum project still has enough PRRT deductions to eliminate its taxable PRRT profit.

That does not automatically prove avoidance or illegality. It demonstrates why the deduction rules determine when the 40% headline rate actually applies.

07What does the 90% deductions cap really do?

For covered offshore LNG projects, the cap generally limits deductions used in a year to 90% of assessable PRRT receipts. At least 10% can therefore remain exposed to the 40% PRRT rate—a possible floor of roughly 4% of assessable receipts.

The unused deductions are delayed rather than deleted. They remain available in later years under the statutory rules. The cap is a real reform, but it does not extinguish the accumulated pool.

08Can related companies shift value through Singapore?

Multinational LNG groups may use related extraction, processing, marketing and sales entities in different jurisdictions, including Singapore. These arrangements are not automatically unlawful, and Australian transfer-pricing rules require related-party dealings to be supportable.

The documented problem is more specific: Treasury found that the former PRRT gas-transfer-pricing formula structurally undervalued gas at the Australian taxing point, particularly when prices were high. That could allocate too little value to the upstream Australian resource before later processing and marketing profits were recognised.

09What changes would materially increase the public return?

Options include stopping uplift after first production, limiting uplift to inflation or the bond rate, placing a time limit on uplift, lowering the deductions cap, introducing a production royalty or export levy, tightening related-party pricing, or creating direct public ownership.

Each option changes investment risk and government revenue differently. The political choice is how much risk the public should absorb and how long it should wait for payment.

Why the anger persists

The promise was prosperity. The result is contested.

Public frustration is not based on one tax number. It comes from the distance between the expectations used to justify the LNG build-out and what many citizens believe they received.

The public case made

  • Hundreds of billions of dollars in investment
  • Construction and long-term regional employment
  • Strong company-tax and resource-rent revenue
  • Reliable domestic gas alongside exports
  • National prosperity from a major export industry

The questions left behind

  • Why have export earnings greatly exceeded annual PRRT receipts?
  • Why can large deduction pools keep growing after production begins?
  • Why did east-coast consumers face supply and price interventions?
  • Why do some major entities report no taxable company income in particular years?
  • Why does Australia lack a national petroleum wealth fund?
The strongest criticism is not that the industry pays nothing. It is that ordinary business taxes are repeatedly presented as the answer to a different question: whether Australians receive an adequate and timely return for surrendering a finite public resource.

Export earnings are gross revenue, not taxable profit. A large gap between exports and PRRT is politically significant, but it is not by itself proof of unlawful tax avoidance.

The global reality check

Australia chose a different model

Norway and Qatar are not perfect like-for-like comparisons. Their geology, markets and political institutions differ. The useful comparison is the set of tools each country uses to capture and preserve resource value.

Public-value leverAustraliaNorwayQatar
State ownershipLimited direct Commonwealth ownershipDirect state participation through SDFI plus majority state ownership of EquinorState-owned QatarEnergy dominates petroleum development
Production paymentMixed state royalties, excise and PRRT treatment; much offshore production has no conventional royaltyTaxes, fees, dividends and direct state field interestsValue captured primarily through state ownership and joint ventures
Profit taxationCompany tax plus 40% PRRT after project deductionsOrdinary company tax plus special petroleum tax; combined marginal rate commonly 78%Fiscal terms and state participation negotiated through QatarEnergy ventures
Cost recoveryProject deductions, uplift and some exploration transfers; 90% cap for covered LNG projectsStructured petroleum-tax deductions without Australia’s legacy PRRT systemProject and joint-venture arrangements determined through state-controlled development
Saving for the futureNo dedicated national petroleum sovereign wealth fundGovernment Pension Fund Global invests petroleum wealth for current and future generationsQatar Investment Authority invests state wealth and supports economic diversification
Domestic policyWA reservation policy; east coast historically lacked an equivalent broad reservationDifferent pipeline-based market and state-management structureProduction and marketing coordinated through the state-owned producer
Norway

Combines high petroleum taxation, direct ownership and disciplined saving. Its sovereign fund’s value passed NOK20 trillion in 2024; investment returns now account for more than half of its value.

Qatar

Captures value through state ownership and controlled joint ventures around an exceptionally large, low-cost gas resource. Its model is fundamentally different from Australia’s private-led project tax.

Australia

Relied more heavily on private investment, ordinary company tax and a back-ended resource-rent tax. That reduced early project risk—but also delayed the Commonwealth return.

Explore the evidence

Forty years of tax rules, projects and political choices#

The overview above gives the argument. This detailed timeline lets you inspect the legislation, project milestones, ministers, reviews and modelled scenarios behind it.

PRRT project Tax policy · Treasurer Petroleum policy · Resources minister

Portfolio guide: Treasury develops PRRT policy and the ATO administers the tax. Resources ministers oversee petroleum, gas and offshore-resource policy. Trade ministers handle trade agreements, export promotion and market access, while foreign-investment screening sits principally with Treasury and the FIRB. Commercial LNG sale contracts are generally signed by project companies and their customers, not by ministers.

1983–91 Treasurer Paul
Keating
1983–84 Resources & Energy Peter Walsh
1984–87 Resources & Energy Gareth Evans

1984Policy

A new bargain for Australia’s petroleum#

The Hawke Government announces a resource-rent-tax policy for new offshore petroleum projects: investors recover legitimate costs and returns, while Australians share in exceptional profits earned from finite resources.

Historical context

1987–88Legislation

The PRRT becomes law#

Parliament enacts the Petroleum Resource Rent Tax Assessment Act 1987. From January 1988, new offshore projects face a 40% tax on taxable project profit after eligible deductions—not 40% of sales or exports.

View the legislation

1989LNG exports

Australia enters the LNG export era#

The North West Shelf begins exporting LNG to Japan. The project is initially outside PRRT and continues under Commonwealth excise and royalty arrangements.

Jun–Dec 1991 Treasurer John Kerin
Dec 1991 Treasurer Ralph Willis
1991–93 Treasurer John Dawkins
1987–91 Primary Industries & Energy John Kerin
1991–93 Primary Industries & Energy Simon Crean

1991–92Tax design

Uplift and transferability reshape the tax#

Exploration deductions become transferable between qualifying projects within company groups. Some exploration spending continues to attract an uplift tied to the long-term bond rate plus 15 percentage points. Bass Strait also moves into PRRT.

Callaghan Review, historical changes
1993–96 Treasurer Ralph
Willis
1996–2007 Treasurer Peter
Costello
1993–96 Primary Industries & Energy Bob Collins
1996–98 Resources & Energy Warwick Parer
1998–2001 Industry, Science & Resources Nick Minchin
2001–07 Industry, Tourism & Resources Ian Macfarlane

1998–2005Gas pricing

How do you price gas before it becomes LNG?#

Integrated LNG projects create a problem: no ordinary sale may occur where upstream gas production ends. Government develops a Residual Pricing Method, followed by formal Gas Transfer Pricing regulations in 2005.

2004Incentive

A 150% frontier exploration incentive#

Eligible exploration in designated remote offshore areas receives a temporary 150% deduction, using PRRT to encourage risk-taking as well as collect revenue.

2007–13 Treasurer Wayne
Swan
2007–13 Resources & Energy Martin
Ferguson

2008–15Investment boom

The LNG construction boom#

Australia approves and builds a generation of enormous LNG projects, including three Queensland export terminals. Their costs create equally enormous deduction pools before substantial PRRT becomes payable.

2010–12Expansion

PRRT is extended across Australia#

The Gillard Government extends PRRT to onshore petroleum, coal-seam gas and the North West Shelf from July 2012. Existing projects receive starting-base deductions recognising prior investment and value.

Jun–Sep 2013 Treasurer Chris Bowen
2013–15 Treasurer Joe
Hockey
2015–18 Treasurer Scott
Morrison
Mar–Sep 2013 Resources & Energy Gary Gray
2013–15 Industry Ian Macfarlane
2015–16 Resources & Energy Josh Frydenberg

2016The paradox

Exports rise. PRRT revenue falls.#

As new LNG production arrives, concern grows that PRRT receipts are declining rather than rising. Some large LNG projects may not pay significant PRRT for decades because their accumulated deductions continue to grow.

2017Review

The Callaghan Review#

The Turnbull Government’s review finds PRRT remains the preferred resource-rent model but is better suited to oil than modern LNG. It recommends reducing excessive uplift rates and modernising the system.

Read the review
2018–22 Treasurer Josh
Frydenberg
2016–20 Resources & Northern Australia Matt Canavan

2019Reform

Uplift rates are reduced#

Parliament reduces several uplift rates and removes onshore petroleum projects from PRRT. The changes limit future compounding, but do not simply erase the legacy stock of accumulated deductions.

View the 2019 Act
2020–22 Resources, Water & Northern Australia Keith Pitt
2022–present Treasurer Jim
Chalmers
2022–present Resources Madeleine
King

2022Global shock

An energy crisis delivers windfall gains#

Russia’s invasion of Ukraine drives international energy prices higher. Australian LNG exporters benefit from elevated prices, intensifying scrutiny of the public return Australia receives from its gas.

2023–25Deductions cap

A minimum payment—eventually#

The Albanese Government limits relevant LNG projects to offsetting 90% of assessable PRRT receipts with deductions. The cap applies from July 2023 and brings some tax forward, subject to the rules for when a project becomes covered.

ATO explanation

2026Campaign

The push for a flat export tax#

The Australia Institute, ACTU, David Pocock, Steph Hodgins-May, Richard Denniss, Konrad Benjamin and others support a 25% tax on gas-export value. The Australia Institute estimates revenue of up to $17 billion a year.

Read the proposal

September 2026Present day

The argument remains unresolved#

A Senate inquiry receives more than 230 submissions but cannot agree on common recommendations. The Government does not adopt the 25% export tax and instead pursues domestic gas-reservation measures.

View the Senate inquiry

The choice now

Australia has spent forty years trying to tax exceptional petroleum profits.

Should it continue repairing that system—or replace complexity with a simple charge on what leaves the country?

What the Commonwealth received

PRRT receipts by financial year

The first receipts arrived in 1989–90. The highest cash result in this official series remains $2.379 billion in 2000–01.

The final two bars are Budget estimates, not actual collections: $1.4 billion for 2025–26 and $1.9 billion for 2026–27.

Actual cash receipts Budget estimate
View the complete data table
Financial yearCash receipts ($m)Status

Source: Parliamentary Budget Office, Historical Fiscal Data—2026–27 Budget , cash-accounting “resource rent taxes” series. The PBO notes that this head combines PRRT and, during its short life, MRRT receipts. Values are nominal and rounded to the nearest $1 million for display.

Revolving Door

From politician to the gas industry payroll

Several federal ministers responsible for resources, energy, trade or closely related policy later accepted employment, lobbying, advisory or board roles in the resources sector.

These career moves do not, by themselves, prove that any minister acted improperly in office. They do raise legitimate questions about access, influence, institutional knowledge and the strength of Australia’s post-ministerial employment rules.

Selected verified examples—federal ministers only
Former ministerRelevant public positionSubsequent resources-industry roleCommencedEvidence
Martin FergusonMinister for Resources and Energy, 2007–2013Chair of the advisory board of APPEA, now Australian Energy Producers2013Australia Institute record
Ian MacfarlaneMinister responsible for industry and resources, 2001–2007 and 2013–2015Chief Executive, Queensland Resources Council; subsequently a Woodside director2016Queensland Resources Council
Gary GrayMinister for Resources and Energy, 2013General Manager, External Affairs, Mineral Resources2016Australian Government biography
Mark VaileMinister for Trade, 1999–2006; Deputy Prime Minister, 2005–2007Chairman and non-executive director, Whitehaven Coal2012Whitehaven corporate record

Scope: this is a selected, evidence-linked list rather than a claim of improper conduct or a complete register of every post-political appointment. “Resources industry” includes oil, gas, coal and mining companies and their peak lobbying bodies.

Language of the system

Terms and acronyms

PRRT debates mix tax law, petroleum engineering and LNG-market language. These are the terms used on this page and in its principal sources.

ACCC
Australian Competition and Consumer Commission
AEMO
Australian Energy Market Operator
ANAO
Australian National Audit Office
ATO
Australian Taxation Office
AUD / A$
Australian dollar
bcm
Billion cubic metres of gas
BTU / MMBtu
British Thermal Unit / one million BTU, a gas-energy measure
Capex
Capital expenditure: spending to develop or expand a project
CCS
Carbon capture and storage
CPI
Consumer Price Index, a measure of consumer-price inflation
CSG
Coal seam gas
EM
Explanatory Memorandum accompanying legislation
ETS
Emissions Trading Scheme
FID
Final Investment Decision: formal approval to proceed with a project
FLNG
Floating liquefied natural gas facility
FOB
Free On Board: price at the export point before freight and insurance
GDP
Gross Domestic Product
GLNG
Gladstone LNG project
GTP
Gas Transfer Pricing: rules for valuing gas before liquefaction
GST
Goods and Services Tax
Ichthys
Ichthys LNG project, often abbreviated ICH
JCC
Japanese Crude Cocktail, an oil-price benchmark used in LNG contracts
JKM
Japan–Korea Marker, a benchmark for spot LNG prices in Asia
LNG
Liquefied natural gas
LRET
Large-scale Renewable Energy Target
LTBR
Long-Term Bond Rate, based on Australian Government bond yields
MoU
Memorandum of Understanding
mtpa
Million tonnes per annum
NOPSEMA
National Offshore Petroleum Safety and Environmental Management Authority
NOPTA
National Offshore Petroleum Titles Administrator
NPV
Net Present Value: today’s value of future cash flows
NWS
North West Shelf project
Opex
Operating expenditure: the ongoing cost of running a project
PBO
Parliamentary Budget Office
PRRT
Petroleum Resource Rent Tax
ROC
Rate of Return on Capital
RPM
Residual Pricing Method used within gas-transfer-pricing rules
Tcf
Trillion cubic feet of gas
ToP
Take-or-Pay: a contract requiring payment for an agreed volume whether taken or not
UDE
Undeducted Expenditure: deductible PRRT expenditure carried forward unused
Uplift
Annual compounding applied to specified unused PRRT deductions
USD / US$
United States dollar
WA
Western Australia

Evidence

Principal sources

  1. Parliamentary Budget Office—Historical Fiscal Data, 2026–27 Budget
  2. Norwegian Offshore Directorate—The Norwegian Government’s petroleum revenues
  3. Norges Bank Investment Management—Government Pension Fund Global
  4. QatarEnergy—State petroleum and LNG enterprise
  5. Qatar Investment Authority—Qatar’s sovereign wealth fund
  6. Western Australian Government—WA Domestic Gas Policy
  7. The Australia Institute—Removing the fossil fuel industry’s influence on politics, 2024
  8. Queensland Resources Council—Ian Macfarlane tenure record, 2023
  9. Australian Government—Gary Gray biographical record, 2020
  10. Australian Treasury—Petroleum Resource Rent Tax Review, Final Report, 2017
  11. Australian National Audit Office—Administration of the PRRT, 2009
  12. Treasury Laws Amendment (2019 Petroleum Resource Rent Tax Reforms No. 1) Act 2019
  13. Treasury—Review of Gas Transfer Pricing Arrangements, 2023
  14. Australian Government—Changes to the PRRT, 7 May 2023
  15. Australian Taxation Office—PRRT deductions cap
  16. Australian Taxation Office—PRRT data in the 2023–24 Corporate Tax Transparency Report
  17. Australian Treasury—current and previous Treasury ministers
  18. Parliamentary Handbook—Commonwealth ministries and portfolio appointments
  19. Department of the Prime Minister and Cabinet—current and recent ministry lists
  20. Senate Select Committee on the Taxation of Gas Resources, 2026
  21. The Australia Institute—Submission on taxing Australia’s gas, 2026

This page distinguishes enacted law and official findings from proposals, estimates and advocacy claims. Advocacy figures are attributed to their originating organisation. Ministerial markers identify portfolio responsibility; they do not imply that an individual minister negotiated a private LNG contract or personally administered a company’s PRRT assessment. Last factual review: 20 September 2026.