LEGAL AND COMMERCIAL SCRUTINY OF THE 2026 DEEP OFFSHORE PRODUCTION TAX INCENTIVES ORDER
Executive Summary
The Deep Offshore Oil and Gas Projects Incentives (Tax Remission) Order, 2026 (the "Order") establishes a production-linked tax remission framework for qualifying deep offshore oil and gas developments in Nigeria. It provides for a Standard Production Tax Credit (Standard PTC) and, for qualifying projects, a Supplementary Production Tax Credit (Supplementary PTC) and a Profit Oil Reset for qualifying Production Sharing Contract (PSC) developments. Access to these incentives is subject to the eligibility and other conditions prescribed by the Order.
The Order is intended to improve the commercial viability of deep offshore developments by reducing the effective fiscal burden on qualifying production and providing greater certainty for investors. The Federal Government has described the framework as a rules-based approach to attracting long-term capital into deep offshore projects, with the potential to unlock significant new investment.
However, the incentives are not automatic or unconditional. Eligibility depends on factors including the nature of the project, the applicable lease, Final The Deep Offshore Oil and Gas Projects Incentives (Tax Remission) Order, 2026 (the "Order") establishes a production-linked tax remission framework for qualifying deep offshore oil and gas developments in Nigeria. It provides for a Standard Production Tax Credit (Standard PTC) and, for qualifying projects, a Supplementary Production Tax Credit (Supplementary PTC) and a Profit Oil Reset for qualifying Production Sharing Contract (PSC) developments. Access to these incentives is subject to the eligibility and other conditions prescribed by the Order.
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