Tax Assessment Objection Lodged with IRC

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Stock ST Barbara Ltd (SBM.ASX)
Release Time 18 Feb 2025, 8:15 a.m.
Price Sensitive Yes
 St Barbara Lodges Tax Assessment Objection with PNG IRC
Key Points
  • Simberi Gold, a St Barbara subsidiary, lodges objection against PNG IRC tax assessments
  • IRC assessed additional tax of PGK152.0 million and penalties of PGK304.1 million
  • St Barbara identifies errors totaling PGK64.0 million in IRC's calculations
Full Summary

St Barbara Limited ('St Barbara') advises that its wholly-owned subsidiary Simberi Gold Company Pty Ltd ('Simberi Gold') has lodged an objection against tax assessments by the Papua New Guinea ('PNG') Internal Revenue Commission ('IRC'). St Barbara and Simberi Gold reject the IRC's arguments, which have been incorrectly applied to the tax legislation underlying the assessments. The IRC assessed additional tax of PGK152.0 million on revisions to Simberi Gold's tax returns from 2017 to 2021, related to Allowable Capital Expenditure ('ACE'), and applied penalties of PGK304.1 million. St Barbara and Simberi Gold have identified errors totaling PGK64.0 million in the IRC's calculations, including omission of pre-production capital, attribution of carry-forward ACE to loss-making years, and erroneous recalculation of historical short-life ACE to long-life ACE. After adjusting for these errors, the remaining disputed amount is PGK88.1 million, related to the IRC's contention on the application of section 155E(4) of the PNG Income Tax Act to accelerated ACE deductions. The IRC has also assessed deemed withholding tax ('DWT') of PGK49.9 million on a capital distribution made by Simberi Gold from 2017 to 2019, with penalties of PGK37.7 million. St Barbara and Simberi Gold have identified an error of PGK35.9 million in the IRC's DWT calculations. Overall, the Company disputes the underlying arguments made by the IRC and rejects the basis for penalties being imposed.