Under the 2017 national budget taxation measures were set in the context of the October 2015 report released by the Taxation Review Committee, following its comprehensive review of tax law and revenue administration in Papua New Guinea. The 2017 national budget included some significant tax changes, and it is expected that further changes will be included in future budgets as the recommendations of the tax review are assessed by the Treasury.
2017 National Budget
The 2017 budget introduced significant tax changes including:
• Implementation of a standard 30% corporate income tax rate for all companies resident in PNG, including those in the extractive industries to which different rates of taxation may have previously applied;
• Reduction of the dividend withholding tax rate from 17% to 15% for all dividends, and removal of some concessions and exemptions that previously applied (mainly to companies in the extractive industries);
• Removal of the dividend withholding tax on dividends paid between PNG resident companies;
• An increase in the withholding tax rate for foreign contractors from 12% to 15%, and removal of the option for foreign contractors to elect to file an income tax return;
• Imposition of a 30% additional profits tax across all mining and petroleum project developments;
• Removal of the exemption from the interest withholding tax for foreign lenders lending to PNGbased resource projects;
• An increase in the taxable amount of high-cost, employer-provided housing benefits; and
• Implementation of the minimum reporting standards applicable to base erosion and profit shifting for multinationals, as per OECD recommendations. There were some unintended consequences of these changes, in relation to dividends taxation in PNG.
Taxation Review Committee
In October 2015 the government received a report from the Taxation Review Committee. The report followed two years of work and research by the body. The stated objectives of the review were the following:
• Align PNG’s revenue system with its aspiration of becoming a competitive middle-income nation in the Asian century;
• Improve the competitiveness and efficiency of PNG’s taxation system to encourage investment and employment growth, including overall economic development;
• Consider options to change the tax mix between the levels of taxation on land, including resources, capital and labour;
• Ensure that PNG’s tax system remains fair, simple, user friendly and equitable; and
• Improve taxpayer compliance by considering options to enhance services to taxpayers and reduce the cost of compliance through the use of modern technology. The Taxation Review Committee’s report suggested a timetable of five years to address the complex nature of the recommendations raised in the report. The committee also acknowledged the very real challenge of ensuring that the tax reform was backed by a solid policy foundation, recommending a number of new bodies be established to provide further guidance. The process for implementation of tax reform commenced under the 2017 national budget, and in addition to the measures already introduced the recommendations of the Taxation Review Committee include the following:
• Introduction of a capital gains tax that will initially apply only to real property, but including resource licences;
• Reducing the corporate income tax rate to 25% over time;
• Reducing personal marginal tax rates;
• Review of the taxation of retirement benefits;
• Increasing the goods and service tax (GST) rate from the current 10%;
• Suspension of the infrastructure tax credit scheme;
• Application of an additional profits tax at a rate of 35% to new mining, oil and gas projects;
• Abolishing the training levy; and
• Removing stamp duties. In addition to legislative and technical changes the Taxation Review Committee has also addressed revenue administration in PNG and made a number of recommendations for improvement in administration at the Internal Revenue Commission (IRC) and Customs. The committee recommends the establishment of a Revenue Administration Board to oversee all revenue administration functions in PNG.
PNG’s tax regime is based on the Income Tax Act, the GST Act, the Customs Act and the Excise Tax Act, and it is supported by related legislation and regulations. Under the Income Tax Act a specific set of rules apply to taxpayers operating in the natural resources sector, namely, the mining, gas and petroleum segments, while the general provisions of the other laws apply to all other taxpayers, as well as to those taxpayers engaged in mining, petroleum or gas operations.
Type Of Corporate Entity
A number of different types of legal entities are available to those looking to do business in PNG. These include incorporating a PNG company (subsidiary), registering locally as an overseas company (PNG branch), entering into a partnership agreement, and establishing a trust. The choice of entity is generally based on the commercial goals of the enterprise, legal and regulatory requirements, and the results for taxation purposes. Most foreign enterprises operating in PNG do so through a subsidiary or branch.
Companies Act Requirements
Where a company incorporated outside of PNG commences to carry on business in PNG it is required on commencement to register as an overseas company under the Companies Act. For the purposes of the Companies Act the term “carrying on business” is given an extended meaning, but otherwise has its ordinary meaning. As a general proposition an overseas company that enters into a contract for work to be done in PNG and undertakes work there for a period of more than 30 days would be regarded as carrying on business in PNG under the act.
Investment Promotion Act
Companies based in PNG and international companies with foreign shareholdings of 50% or more, held or controlled by non-citizens of PNG, or effectively controlled by non-citizens of PNG are required to obtain certification from the Investment Promotion Authority before they can carry on business in the country.
The meaning of carrying on business for the purposes of the Investment Promotion Act, so far as is relevant, is identical to the meaning of carrying on business for the purposes of the Companies Act. It follows that this requirement applies whether an overseas company intends to carry on business in PNG through a subsidiary or through a branch.
A company is deemed a resident for corporate income tax purposes if it meets either the incorporation test or the management and control test. Under the incorporation test, a company incorporated in PNG is automatically regarded as a PNG tax resident. However, the law of another country and a relevant double taxation agreement (DTA) may result in a company also being treated as resident in another country.
Under the management and control test, a company is a tax resident if it is managed and controlled in PNG, regardless of where it is incorporated. Generally, a company is managed and controlled in PNG if key decisions affecting it are made at directors’ meetings held in PNG. This includes a company incorporated outside of PNG that trades in PNG and has its voting power controlled by resident shareholders.
The concept of permanent establishment has limited significance in PNG’s domestic taxation law and is defined to mean a place at or through which a person carries on any business. Under domestic taxation law, PNG will seek to tax the income of a non-resident that is sourced in PNG whether or not that income is derived at or through a permanent establishment in PNG. Where PNG has entered into a DTA, the concept of a permanent establishment becomes more important, as it will then be one of the factors determining PNG’s taxing rights over income sourced in PNG, particularly with respect to the business profits of a non-resident company. Generally, PNG’s DTAs:
• Define a permanent establishment to be a fixed place at or through which the business of an enterprise is wholly or partly carried on; and
• Deem a permanent establishment to exist in various circumstances, including those relating to the presence of substantial equipment in PNG and the time spent by personnel of an enterprise furnishing services in PNG.
Companies that are deemed resident of PNG are liable for income tax on their worldwide income. Companies that are not resident in PNG are only required to pay tax in the country on income sourced in PNG. A non-resident’s PNG-sourced passive income, including dividends, interest and royalties, is generally only subject to withholding tax. Generally, the payer of the dividend, interest or royalty must withhold the relevant amount of the tax and remit this to PNG’s IRC.
Trading profits and other income, except income that is specifically exempt, of resident companies in PNG are assessed tax at a rate of 30%, whereas non-resident companies that carry on operations in PNG are assessed tax at a rate of 48%.
Taxable income is defined as assessable income minus allowable deductions. In practice, profits are calculated for tax purposes by reference to the profits reported in the financial accounts. Accounts must be prepared in accordance with PNG accounting principles, which follow International Financial Reporting Standards.
Dividends are included in the assessable income of a resident company shareholder unless otherwise exempt from corporate income tax. Inter-Company Dividends: Dividends received by a resident company from other companies, whether resident or non-resident, while being assessable to tax, are generally subject to a full tax rebate and are effectively received tax free. However, where a company has sustained losses on other activities or losses have been carried over from earlier years, those losses are applied against dividend income before the calculation of the dividend rebate. While the dividend rebate has legislatively been repealed since January 1, 2017, the Treasury has indicated this was an unintended consequence of the reform of taxation of dividends in the 2017 national budget and the rebate will be reinstated. From January 1, 2017 no dividend withholding tax applies to dividends paid by a PNG resident company to another PNG resident company. Stock Dividends: In most cases, the payment of a dividend by way of the issue of shares is subject to the same taxation treatment as the payment of a dividend by way of cash or the distribution of other property. However, dividends paid by the issue of shares wholly and exclusively out of profits arising from the sale or revaluation of assets not acquired for the purpose of resale at a profit are exempt from income tax and dividend withholding tax.
Unless exempt under specific provisions, any interest paid or credited by a financial institution, the central bank or a company to a person who is resident in PNG is included in income, and the institution or person paying the interest in the account is therefore liable to withhold and pay tax upon the amount.
Generally, foreign exchange gains realised and derived from debts made on or after November 11, 1986 and denominated in a currency other than the PNG kina are included in assessable income. Realised foreign exchange gains on revenue items are included in assessable income.
PNG resident companies are liable for corporate income tax on their income from all sources, including foreign source-derived income. However, a foreign tax credit may be available to offset foreign tax paid against the tax payable in PNG (see tax credits and incentives section below). There are currently no provisions under PNG tax law that permit deferral of the taxation of income derived outside of the country. Subject to the operation of a DTA, foreign-sourced income derived by a resident of PNG is subject to tax in PNG in the same year in which it is derived. This does not change whether or not that income is repatriated to PNG.
General deduction provisions provide that all losses and expenditures, to the extent that they are incurred in gaining or producing the assessable income, or are necessarily incurred in carrying on a business for the purpose of gaining or producing that income, are allowable deductions.
However, the general deduction provisions do not allow a deduction to the extent a loss or expenditure is an outgoing of capital; or of a capital, private or domestic nature; or incurred in relation to the gaining or production of exempt income.
Generally, foreign exchange losses realised and derived from debts made on or after November 11, 1986 and denominated in a currency other than PNG kina are an allowable deduction. Realised foreign exchange losses on revenue items are also allowable deductions.
Thin Capitalisation & Interest Expenses
A deduction is generally available for interest incurred on an arm’s-length basis, subject to meeting the general principles and conditions for deductibility. Where interest is incurred in connection with the construction or acquisition of an item of a plant or a capital asset, that interest is not immediately deductible. Rather, such interest is deemed to form part of the cost of that asset in the case of a plant, and this interest will form part of the base from which future depreciation deductions are claimed.
PNG’s thin capitalisation rules apply to PNG companies across all industries as follows:
• 3:1 permitted debt- to-equity ratio for taxpayers in the natural resource sector, including mining, oil and gas; and
• 2:1 for all other taxpayers. The thin capitalisation rules do not apply to licensed financial institutions. If the permitted ratio is breached, a proportion of interest paid will be denied as a tax deduction.
There is no general capital gains tax in PNG. However, profits arising from the sale of property acquired for the purpose of resale at a profit, or from the carrying out of a profit-making scheme, are taxable as ordinary income.
Net Operating Losses
Domestic trading losses may be offset against all income received in the same accounting period or carried forward and offset against future trading profits. The limitation period on the carrying forward of losses is generally 20 years. Losses may not be carried back against prior years’ profits. Primary production losses and resource project losses may be carried forward without a time limitation, although, again, they may not be carried back (see tax credits and incentives section below). The deduction of losses in all cases is subject to a 50% or more continuity of shareholding and control test, or a continuity of business test where there is a breach of the ownership test.
Foreign losses incurred by a resident taxpayer from a source outside PNG (other than in relation to export market development) are not deductible against assessable income derived within PNG. In practice, overseas losses can be carried forward and offset against overseas income for up to 20 years.
Payments To Foreign Affiliates
The deduction available to a taxpayer for management fees paid to an associated person is limited to the greater of:
• 2% of the assessable income derived from PNG sources by the taxpayer; or
• 2% of the allowable deductions, excluding management fees, incurred by the taxpayer in PNG. Management Fees: The limitation for management fees is applicable to both PNG resident and non-resident taxpayers. Special rules apply to mining, petroleum and gas companies.
These limits may also not apply in situations where the recipient of the management fee is resident in a country with which PNG has a DTA, or where it can be demonstrated that the management fee arrangements do not have the purposes or effect of avoiding or altering income tax payable in PNG.
As with most jurisdictions around the world, withholding taxes comprise an important part of PNG’s tax revenue collection regime. Details of the country’s major withholding taxes and regulations are provided below. Dividend (Withholding) Tax: From January 1, 2017 dividends paid by a PNG company are generally subject to a 15% dividend withholding tax. Dividends paid to PNG resident companies and superannuation funds may be exempt from withholding tax. Interest (Withholding) Tax: Where interest is paid or credited by any person to a non-resident or to a resident, a 15% withholding tax must be deducted. The withholding tax acts as a final tax for non-residents and the rate may be reduced where the recipient is a resident of a country with which PNG has a DTA. Royalty (Withholding) Tax: Tax is imposed on royalties and similar payments made to non-residents who do not have a permanent establishment in the country. The tax must be withheld by the payer on behalf of the payee and remitted to the IRC. The tax payable on royalties to a party who is not an associated person is the lesser of:
• 48% of the net royalty, that is, gross royalty, less applicable expenses; or
• 10% of the gross royalty. Royalty payments to a non-resident associated person are liable for a withholding tax of 30% of gross payments, subject to any DTA, with no option to adopt the net income basis. The definition of associated person is detailed and widely drawn. Broadly, the legal definition encompasses relatives, partners and/ or companies under effective common control and related trust interests. There is also a 5% withholding tax on mining, petroleum, timber and fishing royalties for landowners. Management Fee (Withholding) Tax: A 17% withholding tax applies to management fees and technical fees paid to non-residents. The withholding tax only applies to the amount allowable as a tax deduction. The tax must be remitted to the IRC within 21 days after the month in which such fees are due to be paid or credited. Foreign Contractors Withholding Tax: There are specific provisions included within the Income Tax Act that deal with the taxation of non-residents, other than individuals, which conduct certain contract activities in PNG. Such non-residents are referred to as foreign contractors.
The contract activities include undertaking installation and construction projects, or providing professional and consultancy services in PNG, as well as equipment leases and charter payments. Income derived from these contracts is subject to a 15% foreign contractor withholding tax. The PNG contracting entity must provide the IRC with a copy of a relevant contract within 14 days of its signing, following which the foreign contractor’s withholding tax can be deducted from payment to the foreign contractor. A foreign contractor tax file number application must be lodged with the IRC at the same time. Where tax is withheld from the foreign contractor the deductions are to be remitted to the IRC within 21 days after the end of the month in which the payment was made. Starting on January 1, 2017 foreign contractors no longer have the option under PNG domestic law to lodge an income tax return in PNG and pay tax on net profit, instead of withholding tax.
TAX Non-resident Insurers Tax
Premiums paid to non-resident insurers in respect of insurance contracts on property located in PNG or insured events that can only occur in PNG are subject to tax in the country. The tax is calculated on a deemed taxable income equal to 10% of the gross premium, which is taxed at the non-resident tax rates of 48% ( companies) or 30% (unincorporated associations). Tax treaties may limit the rate of tax applied.
Overseas Shippers Tax
Income derived by overseas shippers or charterers carrying passengers, livestock, mail or goods out of PNG is liable to taxation in PNG. The Overseas Shipping Tax is calculated on a deemed taxable income equal to 5% of the gross income, which is taxable at the non-resident rate of 48% in the case of companies. The IRC may exempt any overseas shipper from this tax if the shipper’s home country itself has an agreement in place to exempt PNG shippers from a similar tax.
PNG has concluded DTAs with Australia, Canada, China, Fiji, Germany, Indonesia, South Korea, Malaysia, New Zealand, Singapore and the UK. However, as of May 2016 Germany had not yet ratified the treaty. Furthermore, PNG has negotiated but not yet ratified a DTA with Thailand.
Rates of tax imposed on payments to non-residents and the liability of non-residents to PNG tax may be affected by a DTA and these rates are summarised in the table to the left. PNG domestic legislation provides an exemption from withholding tax for interest and dividends in certain circumstances. The higher rates quoted are the maximum rates allowable under the DTA; however, the domestic exemption may still apply in some circumstances.
Where transactions involving non-residents are held not to be at arm’s length, the IRC may impose an arm’s length consideration for income tax purposes and determine the source of any income arising from such transactions.
Corporate taxpayers, including companies, superannuation funds, associates and unit trusts, which have transactions or dealings with international related parties that exceed PGK100,000 ($31,700) in an income year, or have aggregated loan balances with the international related parties in excess of PGK2m ($634,000) at any time during an income year, are required to prepare and lodge an international dealings schedule with their income tax return for that year of income.
The international dealings schedule requires disclosures to be made regarding the nature of the transactions with international related parties, the underlying transfer pricing methodologies followed to determine transfer prices and the nature of documentation supporting those pricing methodologies.
Business Income Withholding Tax
Payers who make an eligible payment of PGK5000 ($1590) or more in relation to one contract are required to register with the IRC as a paying authority and attend to the obligations imposed on it under the Income Tax Act.
Broadly, eligible payments are payments from services including construction, road transportation, motor vehicle repairs, joinery services, hiring, and/ or leasing of equipment and security services.
Where a business income payee enters into a contract with a paying authority to perform work or becomes entitled to receive a business income payment and does not produce a certificate of compliance, a 10% business income withholding tax is required to be deducted by the paying authority based on the gross payment. Furthermore, the business income withholding tax deducted must be remitted to the IRC within 14 days after the end of the month in which the tax was deducted.
Tax Credits & Incentives
There are currently a number of tax credits and incentives available. Foreign Tax Credit: A foreign tax credit may be available to offset foreign tax paid against PNG tax payable. The foreign tax credit is limited to either the foreign tax paid or the average PNG tax payable on the foreign income, whichever is less. There is no mechanism to carry forward excess foreign tax credits for utilisation in a subsequent year. Tourist Accommodations: There are incentive available for large-scale tourist accommodation facilities. The tax rate is set at 20% and applies to income derived by a taxpayer from the operation of a largescale tourist accommodation facility or a substantially improved large-scale tourist accommodation facility. The rate applies for 14 years after the end of the year of income in which the taxpayer first derives income from the facility. This incentive only applies to facilities where construction commenced between January 1, 2007 and December 31, 2011. Staff Training Costs: Companies may sometimes take a double deduction for staff training costs. Certain staff training costs, including the cost of full-time training officers and tourism training, are eligible for a double deduction. Export Market Development: There is also a double deduction for export market development costs. Expenditure incurred in the promotion of sale outside of PNG of goods manufactured in the country or incurred in the promotion of tourism are eligible for double deduction. The total tax saving cannot exceed 75% of the expenditure incurred. Infrastructure Development: There is also a tax credit for infrastructure development which is available to companies engaged in agricultural, mining, petroleum, gas and certain tourism activities that incur expenditure on a prescribed infrastructure development.
In the case of taxpayers that are engaged in mining, petroleum and gas operations, the tax credit is limited to a total of 0.75% of the assessable income or the amount of tax payable for the year (in respect of that mining, petroleum or natural gas project), whichever is less. Excess expenditure over the 0.75% or tax payable may be included in the following year’s tax credit claim. Unutilised credits can generally only be carried forward for two years.
In the case of taxpayers engaged in agricultural production, the credit is limited to 1.5% of the assessable income or the amount of tax payable for the year, whichever is less. A prescribed infrastructure development includes a school, aid post, hospital road and other capital assets that have been approved by the Department of National Planning and the IRC.
It cannot be an expenditure required under the Mining Act or the Oil and Gas Act. A 1.25% tax credit scheme is also available for expenditure incurred in connection with the emergency repair of the Highlands Highway. Agriculture Deduction: There is also an agricultural production extension services deduction of 150% for expenditures on services provided free of charge to smallholder growers, including the provision of advice, training and technical assistance in relation to primary production and delivered for the purpose of assisting growers with production, processing, packaging and marketing issues.
Other Tax Incentives
Other tax incentives available in PNG include the following:
• A 10-year tax exemption for qualifying new business located in prescribed remote areas of PNG;
• 100% deduction for most capital expenditure on primary production;
• Exemption of income derived from the export of certain manufactured goods;
• Immediate deduction for the costs of acquiring and installing solar heating plants; and
• A specific deduction for environmental protection and clean-up costs.
Taxation & Other Entities
PNG tax law provides specific criteria and tax regulations for different types of corporate entities. Partnerships: A partnership includes any association of persons in receipt of income jointly. The members of a partnership must include their individual share of the profit or loss of the partnership in their own tax returns. The partnership itself is not subject to tax, although it is required to file a tax return. Joint Ventures: Unincorporated joint ventures are permitted to carry on mining and petroleum operations, and the respective joint venture partners are assessed on their individual share of income on a project basis. Joint venture operators of a resource project are required to submit a consolidated financial statement for the joint venture as a whole, within two months of the end of the year of income. This consolidated financial statement must enumerate details of all expenditure incurred throughout the year. Furthermore, each joint venture partner will be required to reconcile their tax return to the consolidated financial statement. The joint venture itself is not subject to tax and is not required to file an income tax return. Trusts: A trustee of a resident trust estate is taxed on the net income of the trust estate at a rate of 30%. The beneficiaries of a trust estate are also subject to income tax on their entitlement to the net income and on actual distribution. Landowner Resources Trusts: Where interests in various natural resources projects are held in trust for landowners, a trust may be approved by the minister of finance to be a landowner resources trust. Net income derived by the landowner resources trust is taxed at a rate of 25%. The tax is payable by the trustee. Distributions of income and capital by a landowner resources trust to its beneficiaries are exempt from income tax in the hands of the beneficiaries. Superannuation Funds: A superannuation fund is resident if it is established or managed in PNG. The taxable income of a resident superannuation fund is subject to tax at a rate of 25%. Dividends paid to a superannuation fund qualify for the dividend rebate, assuming it is reinstated. Where an employer’s contributions to a superannuation fund exceed 15% of an employee’s fully taxed salary or wages, the excess contribution is included as assessable income of the superannuation fund.
PNG taxation applies to individuals. However, the scope and tax rates that apply are dependent on the resident status of the individual and the source from which their income is derived. For individuals who are residents of PNG, PNG taxation applies to their worldwide income at marginal tax rates. Non-residents, however, are only taxed on income that is sourced in PNG, and at different tax rates to those which residents are subject to. In broad terms, an individual will be treated as a resident of PNG in a given year of income if they spend, continuously or intermittently, more than six months in the country during that year. The tax rates for PNG resident and non-resident individuals who are classed as residents are listed in the table below. Assessable Income: Each individual is assessed separately, and there is no joint assessment for spouses. Taxpayers who have only employment income and are fully taxed at source via salary or wages tax do not need to complete an annual income tax return. Taxpayers with other income such as interest, dividends, rental income, trust distribution or partnership income must file an annual income tax return. Employee Benefits: In terms of benefits provided to employees, certain benefits are taxed in the hands of the employees at prescribed values. These benefits include accommodation, housing allowance, motor vehicle, education expenses, leave fares, meals, telephone, cash allowances and contributions by employer to an approved or overseas superannuation fund. Other fringe benefits such as the provision of entertainment, club subscriptions, domestic electricity and domestic services are not deductible to the employer for income tax purposes.
Broadly, PNG’s GST is imposed at a rate of 10% on the supply of most goods and services in the country. The GST Act, which went into force in 2003, defines the term supply as including all forms of supply, such as the sale, transfer, hire or lease of goods, as well as the provision of services. A supply for GST purposes falls into one of the three categories, which are listed below:
• Taxable supply, which falls under the 10% GST rate;
• Zero-rated supply, which attracts a rate of 0%; and
• Exempt supply, which is not subject to GST. Where a taxable or zero-rated supply is made, a registered person is entitled to a credit for the input tax paid on goods or services used in making the supply. Where an exempt supply is made, GST is not charged in respect of that supply. However, no entitlement exists to allow for recovery of any input tax that is paid on goods or services used in generating the supply in question. Businesses having an annual turnover of at least PGK250,000 ($79,300) are required to register for GST, while businesses with annual income of less than PGK250,000 ($79,300) can register voluntarily. Persons or companies that are not registered are not permitted to charge GST. Training Levy: All businesses whose annual payroll exceeds PGK200,000 ($63,400) are subject to a 2% training levy, which is calculated on the sum of the taxable salary and/or wages, including benefits, of all personnel. The levy is assessed on an annual basis. The amount of the levy payable is reduced by the amount of qualifying training expenses incurred in the training of employees who are PNG citizens.
Customs duties are imposed at varying rates on the cost, insurance and freight value of imports. With the introduction of GST, the majority of manufacturing inputs attracts no duty, and duty is now primarily imposed on items which are produced locally in PNG. Duty can be deferred where goods are to be imported and re-exported within 12 months (or some other period as approved by Customs) subject to the approval of the Collector of Customs. A bond must be provided.
Excise, at varying rates, is imposed on certain locally manufactured and imported goods, primarily alcohol, tobacco and fuel products, as well as on goods deemed to be luxury items.
Stamp duty applies at varying rates on documents and transactions. Of note is duty charged on the conveyance of real property, which rises to a maximum of 5% where the value of the real property being transferred exceeds PGK100,000 ($31,700). The duty is payable by the purchaser, and a 5% duty on the unencumbered value of land may also be payable where there is a transfer of shares in certain landholding companies. Other dutiable transactions include share transfers, including some share buy-backs, subject to a rate of 1%. Leases of goods are also subject to stamp duty at a rate up to 1% of the rentals payable, depending on the term of the lease. Stamp duty is also payable on documents executed outside of PNG that relate to property or matters done or to be done within the country.
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