Commercial Oil Operations

Legal Regime – Changes to state org structure (Core organizations only)

Current Legal Regime

Proposed Legal Regime

Fiscal/Legal Regulation

Technical/ Upstream Regulation

Midstream/ Gas Regulation

Policy Downstream Regulation

Commercial Gas Operations

Commercial Downstream Operations

Commercial Oil Operations

Fiscal/Legal Regulation

Technical/ Upstream Regulation

Midstream/ Gas Regulation

Policy Downstream Regulation

Commercial Gas Operations

Commercial Downstream Operations

National Petroleum Directorate

National Petroleum

Company of Nigeria

Ministry of Petroleum Resources

National Petroleum Investment

Management Services

Nigeria Petroleum

Asset Management

Agency

Department of Petroleum Resources

Nigeria Liquid Natural Gas

National Petroleum

Inspectorate

Nigeria Liquid Natural Gas

Nigerian Midstream Regulatory

Agency

National Transport Logistics

Company

Petroleum Products

Regulatory Authority

Nigerian Petroleum

Development Company

Nigerian National Petroleum Company

Pipelines and Products

Marketing Company

49%

49%

Current Fiscal Regime Proposed Fiscal Regime ^^

TAXATION JV Oil JV Gas PSC JV Oil JV Gas PSC

Petroleum Profits Tax* 85% 30% 50% - - -

Nigerian Hydrocarbon Tax** - - - 50% 50% 30%

Corporate Income Tax*** - - - 30%

Dividend Tax - - - 10%

ROYALTIES

Production Royalty 16.7-20% 5%-7% 0-16.7% 5-25%^

Price Royalty - - - 0-25%

Concession Rental $10-$20/km2 Up to $1000/km2

Institutional Levy - - - 2%* Tax calculated on lifting, not on production

** Tax calculated on production, not lifting. Min take of 2% of gross revenue

*** NHT not deductible when calculating CITA payable

^ capped at 20% for existing producing onshore and at 18.5% for shallow water

^^ Refers to revised version of PIB as per OPTS Senate Memorandum on the Review of S.B. 236 (Petroleum Industry Bill)

Fiscal Regime – Proposed changes to taxation and royalty codes