REL — Resource Extraction Levy Simplified For All Australians
A proposal. One levy on the sale value of the ore, at marginal rates set per commodity and stepped by the market price at the time of sale — replacing eight state royalty regimes, the Petroleum Resource Rent Tax, company tax on extraction, and the Commonwealth offshore boundary that splits one industry across two systems. One system, divided where it is collected: 73 per cent Commonwealth, 25 per cent the state the ore came from, 2 per cent Traditional Owners.
New section 11.7, on why the design removes the reason to under-price rather than merely policing it: the levy is fixed by published benchmark and assayed grade, so a producer keeps every additional dollar of realised price and a related-party sale saves no tax. It also names the two incentives that do survive — grade classification and the downstream boundary. Two sources added.
New text is marked in blue.
REL — Resource Extraction Levy, the instrument proposed here. PRRT — Petroleum Resource Rent Tax, the Commonwealth's profit-based tax on offshore petroleum. GST — Goods and Services Tax. HFE — horizontal fiscal equalisation, the principle behind the current GST distribution. CGC — Commonwealth Grants Commission, which administers that distribution. ABS — Australian Bureau of Statistics.
LNG — liquefied natural gas. CSG — coal seam gas. NOPTA — National Offshore Petroleum Titles Administrator. EBRIT — earnings before royalty and income tax (EBRIT). SBC — Sovereign Build Corporation. GJ — gigajoule, the unit gas is priced in; bbl — barrel, for oil; oz — troy ounce, for gold; t — tonne.
1. The proposal, and the case for it
1.1 Queensland has already proved it works
In June 2022 Queensland added three progressive tiers to its coal royalty, charging 20 per cent above $175 a tonne, 30 per cent above $225 and 40 per cent above $300. The rate applies only to the slice of price inside each band, so a producer selling at $150 pays what it paid before. It passed the parliament without a single vote against it — not from the Liberal National Party, not from Katter's Australian Party, not One Nation, not the Greens.
Two years earlier Queensland had replaced its 12.5 per cent wellhead-value gas royalty with a volume-based charge where the rate is set by a price tier. Same principle, different commodity.
Between them those two instruments collected $12.6 billion in 2023–24 — more than New South Wales, South Australia, Victoria, Tasmania and the Northern Territory combined, and more than the entire Commonwealth take from offshore petroleum since 2020. The Queensland Resources Council ran an advertising campaign against the coal change, funded by a levy on its own members, intended to run until the 2024 state election.
The regime is still in place. In 2024 the parliament went further and legislated that the rates cannot be reduced without its approval.
The design is not theoretical and it is not radical. It is Queensland's, it has four years of operating history, and what one state does for two commodities can be done nationally for all of them.
1.2 Gas and oil do not pay their share
Australia's entire public take from oil and gas — the Petroleum Resource Rent Tax, Queensland's petroleum royalty and Western Australia's North West Shelf grants combined — came to $19 billion over the five years to 2024–25. About $3.8 billion a year, against exports running above $80 billion.
That is approximately 4.7 per cent of the value of what is sold. Iron ore is charged 7.5 per cent of value in Western Australia before company tax is counted. Queensland coal is charged above 20 per cent. Gold, copper, lithium and every other commodity in this country is charged more than gas.
There is no principle behind that. It is the residue of a profit-based tax designed in 1987 for a different industry, which allows deductions to accumulate faster than liability. Correcting it is the single largest change in this proposal and the one least likely to be contested by any state, because almost none of the current take goes to one.
1.3 The Commonwealth boundary makes it complicated for no gain
Three nautical miles offshore, the same gas becomes a different legal object. Onshore it attracts a state royalty; offshore it attracts a Commonwealth royalty and a Commonwealth profit tax. A single company operating a single processing plant can be paying under both systems, on different bases, with different deductions, different returns and different disputes.
Nothing about the resource changes at that line. Nothing about the cost of extracting it changes. The boundary exists because of how Australian federation settled ownership of the seabed in the 1970s, and it has been generating compliance work ever since.
One schedule applies on both sides of it. Same base, same bands, same calculation, whether the gas came from the Cooper Basin or the Browse. The state share still follows the ground the resource came out of — and for offshore, the adjacent areas that determine which state that is already exist in Commonwealth law. Removing the boundary from the REL does not require redrawing a map or resolving a constitutional question. It requires deciding that one industry should face one system.
It also changes who wants the project built. A state hosting an offshore development today supplies the land, the port, the roads, the power and the workforce, absorbs the environmental argument, and collects nothing from the resource because the resource is Commonwealth. Give that state a share of what is produced in its adjacent area and it has the same interest in the project proceeding as the proponent does. Section 11.3 sets out what that changes.
1.4 What is proposed
One levy — the Resource Extraction Levy, the REL — replacing the eight state and territory royalty regimes, the Petroleum Resource Rent Tax and company income tax on extraction. Not added to them, instead of them.
The REL is charged on the sale value of the ore at first arm's-length sale, with no deductions. The rate is marginal, in the structure of the income tax system: four bands per commodity, with the thresholds set as multiples of that commodity's ten-year average price, so the schedule indexes itself and no producer ever pays the headline rate on their whole revenue.
The band is set by the market price at the time of sale, against a published benchmark. The same schedule applies onshore and offshore.
The Commonwealth collects the REL nationally and distributes it by a formula fixed in legislation: 73 per cent to the Commonwealth, 25 per cent to the jurisdiction the resource came from, 2 per cent to the Traditional Owner Services Fund. The state share follows production, including offshore production in that state's adjacent area.
It travels with a second reform — the GST rate rising to 12 per cent and its distribution replaced by a single rule, that GST returns to the state where it was spent.
At the illustrative rates in section 7 it collects $103.7 billion a year against $63.9 billion today.
1.5 What it delivers
Set out in full at section 11. In short:
- Australians — forty billion dollars a year more, on a base that cannot be engineered.
- The industry — a rate knowable thirty years out, one calculation instead of three, and a floor band that no existing royalty offers.
- New projects — nothing left to negotiate on price or on the Traditional Owner payment, and approvals on a six-month clock.
- The states — the equalisation clawback ends, and a state that hosts a project finally shares in what it produces.
- Traditional Owners — $2.07 billion a year paid automatically, against $200 to $400 million in statutory entitlements today.
The last of those is the one most easily missed. A state today supplies the land, the port, the roads, the power and the workforce for an offshore development, and collects nothing from the resource. Then it loses GST for whatever else it raises. Under the REL every project that proceeds makes the state better off, and nothing is taken back — which matters, because states control planning, ports, industrial land and environmental approval.
1.6 Why the states would agree
A reform of this kind is usually assumed to be impossible because the states will not consent. The arithmetic in sections 9 and 10 says otherwise, and the reason is that the REL and the GST reform travel together.
On the levy alone every state is worse off, because it gives up a royalty it keeps in full for a share of a levy it does not. With the GST change attached, New South Wales finishes $8.1 billion ahead, Western Australia $3.0 billion and Victoria $1.4 billion. New South Wales and Victoria are ahead on the GST change by itself, before a dollar of levy is counted.
Western Australia — the state that gives up the largest royalty in the country — finishes ahead because it also hosts most of the offshore production and because the equalisation formula it has fought for twenty years is abolished.
Queensland finishes $1.1 billion behind on 2023–24 figures and ahead on 2024–25 ones. That is not evasion; it is what a royalty base that moved from $15.36 billion to $5.4 billion in two years does to any comparison. Section 10 sets out the three ways it is resolved.
South Australia, Tasmania and the Northern Territory cannot be made whole by any levy percentage, because their gap is a GST gap rather than a resource one. They are answered by direct Commonwealth funding, legislated and costed alongside the REL rather than after it. That is a condition of the reform, not a footnote to it, and it is set out at section 10.2.
Beyond the arithmetic there is the standing incentive. Under the present arrangement a state is punished at the margin for developing its resources. Under this one it is rewarded for it, permanently and without clawback. That is a more durable basis for agreement than any one year's numbers.
2. How Australia charges today
A resource project in Australia is taxed three times, on three different bases, by two levels of government. What each jurisdiction charges, under which Act, and what it collects is set out in full in Memo 3, What Australia Charges For Its Resources. This memo takes that record as given and states only what the proposal has to replace.
A royalty is charged by the state or territory that owns the mineral, on the value of what is extracted, at a rate between 1.9 and 7.5 per cent depending on the jurisdiction and the degree of processing. The rate does not change with the price, so the share taken at $220 a tonne is the same share taken at $80.
The Petroleum Resource Rent Tax is charged by the Commonwealth on offshore petroleum profit, after deductions. Because the deductions include an uplift on undeducted expenditure, projects can carry forward credits for many years. The tax has collected little from Australian LNG.
Company income tax is charged at 30 per cent on the profit that remains after royalties, costs, depreciation and interest.
Each instrument has its own base, its own definitions, its own valuation rules and its own dispute history. Compliance is duplicated across eight jurisdictions. The profit-based components can be reduced by debt structuring, transfer pricing, depreciation timing and expenditure uplift — all of it legal, all of it contested, and much of it litigated for a decade at a time.
Australia's own experience is instructive. The Minerals Resource Rent Tax, legislated in 2012, permitted companies to credit state royalties against the federal tax. The states raised their royalties, companies credited the increase, and the Commonwealth collected almost nothing. The tax was repealed in 2014.
The rates, the legislation behind them, the revenue each jurisdiction collects and the Traditional Owner entitlement in each are documented in Memo 3. Nothing in the sections that follow depends on a figure that is not sourced there or in section 13.
3. The base — sale value of the ore
The levy is charged on the sale value of the ore. Tonnes sold, multiplied by the price at which they were sold. Nothing is deducted.
This is not a harsher base than profit. It is an unavoidable one. Profit is a calculated figure: it moves with depreciation schedules, financing arrangements, related-party service fees, marketing hubs and the timing of capital expenditure. Sale value is an observed figure that appears on the invoice. It cannot be engineered, which is the entire point.
Two rules keep it that way.
No deductions of any kind are permitted against the base. The rule is stated on the face of the Act, not left to regulation. Every exception creates a place to argue, and the accumulated exceptions are what the current system consists of.
The REL applies at first arm's-length sale of ore or concentrate. Everything downstream of that point — smelting, refining, manufacturing — is outside the REL and taxed normally. The boundary must be defined in the Act, because a vertically integrated producer will otherwise argue about where extraction ends.
4. Marginal bands
The levy is charged at marginal rates, in the same structure as personal income tax. A rate applies only to the portion of the price that falls inside its band, not to the whole price.
This is a correctness requirement rather than a preference. Under a whole-of-price structure, crossing a threshold applies the higher rate to the entire sale, which produces three failures: total revenue to the producer can fall as the price rises, a one-dollar movement in price can shift tens of dollars a tonne in liability, and every producer acquires a direct financial interest in reporting a price just below the threshold. Marginal bands eliminate all three.
It is also the answer to the headline. Queensland's coal royalty is widely described as a 40 per cent regime because 40 per cent is the top tier. The tiers are marginal, so the top rate applies only to value above $300 a tonne. The Institute for Energy Economics and Financial Analysis calculated the average effective rate on Queensland coal prices in 2024 at approximately 20 per cent, and coal selling below $150 a tonne is taxed as it was before the tiers were introduced.
There is no single top rate. The peak band is set per commodity against what that commodity can carry — 20 per cent on nickel, 24 on lithium, 32 on copper, 38 on gold, 50 on iron ore, 55 on gas and oil, and 65 on coal. Each applies only to the top slice of price in a high market, and none of them is the rate anyone pays on their revenue. The schedule is at section 7.
5. The trigger — market price at the time of sale
The band is determined by the market price at the time the ore is sold. Not a quarterly average, not a rolling average, not a ministerial declaration, and not a forecast.
The thresholds themselves are set as multiples of each commodity's ten-year average price. That is what indexes them, and what allows one schedule to cover commodities traded in tonnes, gigajoules, ounces and barrels. The average sets where the bands sit. The price on the day of sale determines which band applies, and the levy is charged on the actual sale value.
The price is taken from a published independent benchmark for each commodity — the established price indices already used across the industry for contract settlement. The producer's own realised price is used where it is higher than the benchmark, which prevents related-party under-invoicing while allowing for legitimate grade discounts.
Three mechanical points determine whether this works in practice.
Thresholds are indexed. Fixed dollar thresholds drag producers into higher bands through inflation alone, which is bracket creep and is inconsistent with the position Sovereign Australia takes on income tax. Thresholds move automatically with a published index.
Thresholds are denominated in Australian dollars and converted at a published Reserve Bank rate. Commodity benchmarks are quoted in United States dollars. Without this, a falling exchange rate pushes producers into higher bands with no rise in the real price — a distortion the Western Australian royalty system already avoids in the same way.
The reference is the delivery month, not the transaction date, which removes any incentive to time a shipment around a price movement.
6. One instrument, not three
The levy replaces the state or territory royalty, the Petroleum Resource Rent Tax, and company income tax on extraction. It is not charged in addition to them.
This is the point at which the rate has to be compared honestly. A 50 per cent top marginal band on iron ore is not a six-fold increase on a 7.5 per cent royalty, because it is not replacing only the royalty. The correct comparison is total government take against total government take.
A low-cost iron ore producer selling at $100 a tonne with all-in costs near $35 currently pays a royalty of 7.5 per cent, or $7.50, and company tax at 30 per cent on the remaining pre-tax profit of $57.50, or $17.25. Total take is approximately $24.75 a tonne, or about 25 per cent of the sale value — collected through two instruments, on two different bases, after a profit calculation that is separately contestable.
The proposal is to collect a comparable or somewhat larger amount through one calculation that cannot be reduced by structuring.
The band thresholds and rates below demonstrate the structure. They have not been modelled against industry cost curves and are not a policy commitment. The final schedule must be set against the actual cost distribution of Australian producers, so that the REL captures a rising share of a rising price without closing higher-cost operations at the bottom of the cycle.
7. The rate, commodity by commodity
There is one rate structure and it works the way income tax works. Every commodity has a set of thresholds and a marginal rate inside each band. Nobody pays the top rate on their whole revenue — it applies only to the slice of price above the threshold, exactly as the top income tax bracket applies only to the income above it.
7.1 The structure
Four bands, with the thresholds set as multiples of that commodity's long-run price — its ten-year average. That single device does the work of a separate schedule for every commodity:
| Band | Applies to the slice of price | What it is for |
|---|---|---|
| Floor | Below 0.6× the long-run price | Keeps marginal operations open through a collapse |
| Base | 0.6× to 1.0× | Ordinary trading conditions |
| High | 1.0× to 1.5× | Prices above the historical norm |
| Peak | Above 1.5× | The windfall band |
The floor band is the equivalent of the tax-free threshold in the income tax system, and it does the same job: it protects the bottom of the range so that a producer in trouble is not finished off by the charge.
Because the thresholds are multiples rather than dollar figures, the schedule indexes itself, needs no re-legislating as prices move, and applies to iron ore and lithium off the same rule. The dollar thresholds for each commodity are published annually, derived from the rule — a producer gets a table with real numbers, and the Act never changes.
7.2 The schedule
Marginal rates are set per commodity, because commodities differ in what they cost to produce and what they are charged today. Long-run and current prices are per tonne except gold and copper, which are per ounce and per tonne of metal, and gas, which is per gigajoule. Export earnings are 2024–25.
| Commodity | Price — long-run / now | Band rates % | Effective | Sale value | Levy |
|---|---|---|---|---|---|
| Iron ore | $90 / $105 /t | 15 / 30 / 40 / 50 | 23.7% | $117b | $27.7b |
| LNG and gas | $12 / $13 /GJ | 20 / 35 / 45 / 55 | 27.5% | $80b | $22.0b |
| Metallurgical coal | $200 / $200 /t | 30 / 52 / 60 / 65 | 38.8% | $45b | $17.5b |
| Thermal coal | $120 / $120 /t | 30 / 52 / 60 / 65 | 38.8% | $39b | $15.1b |
| Gold | $2,600 / $4,200 /oz | 12 / 22 / 30 / 38 | 21.9% | $45b | $9.9b |
| Oil and condensate | $80 / $75 /bbl | 20 / 35 / 45 / 55 | 25.4% | $15b | $3.8b |
| Copper | $9,000 / $9,800 /t | 10 / 18 / 25 / 32 | 14.2% | $14b | $2.0b |
| Alumina and bauxite | $400 / $450 /t | 8 / 14 / 20 / 26 | 11.5% | $13b | $1.5b |
| Lithium | $1,200 / $900 /t | 6 / 12 / 18 / 24 | 7.2% | $4.8b | $0.3b |
| Nickel | $18,000 / $15,500 /t | 5 / 10 / 15 / 20 | 6.5% | $2b | $0.1b |
| Other metals and critical minerals | various | grouped | 15% | $21.3b | $3.2b |
| Construction and quarry | various | grouped | 5% | $12b | $0.6b |
| Total | 25.4% | $408b | $103.7b |
Long-run price is the ten-year average, which sets where the thresholds sit; the levy is charged on the actual price at sale. Prices are per tonne (/t), gigajoule (/GJ), ounce (/oz) and barrel (/bbl). Band rates are the four marginal rates on the floor, base, high and peak slices of price. Other metals and critical minerals covers zinc, lead, silver, mineral sands, uranium and critical minerals at a flat 15 per cent; construction and quarry at 5 per cent.
The levy applies to the sale value at first arm's-length sale, so the base is exports plus domestic sales — thermal coal to Australian power stations, gas to the domestic market, quarry materials sold locally. That comes to approximately $408 billion: $371 billion of exports and $37 billion domestic.
It is deliberately smaller than the $492 billion the Australian Bureau of Statistics reports as mining sales, because that figure includes mining support services, exploration and intra-industry sales, none of which is a sale of ore at first arm's length.
7.3 How the schedule behaves
Worked on iron ore at a $90 long-run price, so the thresholds fall at $54, $90 and $135. The rows are a collapse, the long-run price, today, 1.5 times long-run, and a boom.
| Iron ore price | Bands applied | Levy | Effective |
|---|---|---|---|
| $50 | $50 at 15% | $7.50 | 15.0% |
| $90 | $54 at 15% + $36 at 30% | $18.90 | 21.0% |
| $105 | $8.10 + $10.80 + $15 at 40% | $24.90 | 23.7% |
| $135 | $8.10 + $10.80 + $18.00 | $36.90 | 27.3% |
| $200 | $36.90 + $65 at 50% | $69.40 | 34.7% |
The effective rate runs from 15 per cent in a collapse to 35 per cent in a boom, on a top marginal rate of 50.
The REL takes a rising share of a rising price and falls away when the price falls, and no producer ever pays the headline rate on their revenue.
7.4 Why the rates differ between commodities
Coal and gas are set against what Queensland already charges. Queensland is the only jurisdiction in the country that charges a serious rate on either. Its coal tiers reach 40 per cent above $300 a tonne and collected $11.1 billion in 2023–24 on roughly $38 billion of coal exports — an effective rate near 29 per cent.
Its gas royalty is a volume-based charge with the rate set by a price tier, the same structure proposed here, and it collects around $1.5 billion. Both are the national benchmark because both already work.
Iron ore sits at 15 / 30 / 40 / 50, producing 23.7 per cent against the 7.5 per cent of value it is charged today. Iron ore, coal and gas together produce $75.7 billion — four fifths of the pool.
Gold's band rates are lower but its price is high, sitting above 1.5 times its long-run average, so it lands at 21.9 per cent against a current royalty of 2.5 per cent in Western Australia. The schedule captures the gold price without needing a special rule for it.
Nickel and lithium are deliberately light. Both are trading below their long-run prices, so both sit in the floor band and pay 6 to 7 per cent. Several Australian nickel operations have suspended production. A levy is a cost whether or not the operation profits, which is precisely why the floor band exists.
Long-run prices here are approximate ten-year averages and the band rates are illustrative. Both need setting against published price series and the cost curve of each commodity before adoption. The structure is the proposal; these numbers demonstrate how it behaves.
8. The total take
At those rates the REL collects approximately $103.7 billion a year — 25.4 per cent of the $408 billion sale value it applies to.
| What it replaces | Collected today |
|---|---|
| Mineral royalty to states and territories | $26.9b |
| Petroleum royalty to states and territories | $2.6b |
| Company tax on extraction | $32.5b |
| PRRT and the Commonwealth share of North West Shelf royalty | $1.9b |
| Total | $63.9b |
| Measure | Today | Under the REL | Change |
|---|---|---|---|
| Total public take | $63.9b | $103.7b | +$40b |
| Share of earnings before royalty and tax | 32% | 52% | +20pts |
| Retained by the industry | $135b | $95b | −30% |
That is the honest headline. The public take rises by nearly two thirds. The industry keeps seven tenths of what it keeps now, pays through one calculation instead of three, and gets a published schedule it can model for thirty years.
These rates sit at the top of the workable range and may sit above it. A levy taking 52 per cent of earnings before royalty and income tax is a substantial change from 32 per cent, and the industry retaining $95 billion against $135 billion is a 30 per cent reduction. Modelling against commodity cost curves may show the coal and gas bands need trimming. The structure is the proposal; these rates demonstrate how it behaves and are not a commitment.
8.1 What gas pays today
One line in that table is worth separating out. Australia's entire public take from oil and gas — the Petroleum Resource Rent Tax, Queensland's petroleum royalty and Western Australia's North West Shelf grants combined — came to $19 billion over the five years to 2024–25. That is approximately $3.8 billion a year, against liquefied natural gas, oil and condensate exports running above $80 billion a year.
The public receives about 4.7 per cent of the value of Australian gas and oil exports. Every other commodity in section 7 is charged more than that, most of them several times more. Iron ore is charged 7.5 per cent of value in Western Australia before company tax; Queensland coal is charged upwards of 20 per cent.
The REL charges gas at 27.5 per cent at current prices. That is the single biggest source of additional revenue in the model — $22.0 billion from LNG and gas against roughly $3 billion collected from the same production today. It is also the change least likely to be contested by any state, because almost none of the current take goes to one.
The proposition is not novel. In March 2026 the Australian Council of Trade Unions called for the Petroleum Resource Rent Tax to be replaced with a 25 per cent revenue-based export levy on liquefied natural gas — a position supported by the shadow minister for industry. The rate proposed here sits just above that, and applies to domestic sales as well as exports.
9. The split — Commonwealth, states, Traditional Owners
The Commonwealth collects the levy from every operation in the country and distributes it by a formula fixed in legislation. One collection, one formula, automatic. No annual negotiation, no state-by-state deals, no royalty disputes.
| Recipient | Share | Amount | Today |
|---|---|---|---|
| Commonwealth | 73% | $75.7b | $35.9b |
| States and territories | 25% | $25.9b | $29.5b |
| Traditional Owners | 2% | $2.07b | under $0.6b |
The Commonwealth figure today is $34.0 billion in company tax on extraction plus $1.9 billion in Petroleum Resource Rent Tax and its share of North West Shelf royalty. The state figure is all royalty, minerals and petroleum. The Traditional Owner figure is available in two jurisdictions only. Of the states' $25.9 billion, $21.8 billion comes from onshore production and $4.1 billion from the offshore fields in their adjacent areas.
9.1 The state share, worked
A state receives 25 per cent of the REL raised on what came out of its own ground — not a national pool divided by need, not an assessment of fiscal capacity.
Offshore is treated the same way as everything else. There is no separate federal rule for it and it is not pooled and shared. The state component of the offshore levy goes to the jurisdiction the production comes from, on the same rule as onshore: the share follows the ground it came out of.
The boundary already exists and does not need drawing. The Offshore Petroleum and Greenhouse Gas Storage Act 2006 divides Commonwealth waters into an adjacent area for each state and the Northern Territory. Every offshore title is already administered against those areas, the joint authorities are constituted on them, and the National Offshore Petroleum Titles Administrator (NOPTA) works to them daily. The levy share follows the adjacent area a field sits in. No new boundary, no formula, no discretion.
On that basis Western Australia takes the largest share — the North West Shelf, Carnarvon and Browse fields sit in its adjacent area — with the Northern Territory taking Bonaparte and Victoria taking Bass Strait.
That removes the exception that would otherwise have left the Commonwealth taking 77 per cent while the schedule said 73, and it applies one rule rather than two. It also reflects where the cost sits: the processing trains, ports, roads, power and towns that make offshore gas sellable are built on state ground and paid for by state governments. Karratha, Darwin and Barrow Island are not Commonwealth infrastructure.
The rule cuts against that principle in one case. Ichthys sits in Western Australia's adjacent area in the Browse Basin, and its gas travels 890 kilometres by pipeline to Darwin, where the Northern Territory hosts the plant, the port and the workforce.
Under an adjacent-area rule Western Australia receives the REL share. The alternative — allocating by where the gas comes ashore — would reverse that, but it would require a new rule where the adjacent areas already exist and are uncontested.
The judgement here is that a settled boundary is worth more than a marginally better fit, and that the Northern Territory's position is properly answered by the direct funding in section 9.2 rather than by redrawing a map.
The table below compares the two systems. The last column is what each jurisdiction collects in royalty today; the middle column is what it would receive from the REL instead. The REL replaces royalty rather than sitting on top of it, so the comparison is between the two, not a sum of them. Section 10 adds the third component, the change in each jurisdiction’s GST.
| Jurisdiction | Levy raised on its production | Its 25% share | All royalty today |
|---|---|---|---|
| Western Australia | $36.6b | $9.15b | $12.79b |
| Queensland | $25.0b | $6.24b | $12.57b |
| New South Wales | $15.6b | $3.90b | $3.10b |
| Victoria | $1.33b | $0.33b | $0.19b |
| South Australia | $1.20b | $0.30b | $0.52b |
| Northern Territory | $0.94b | $0.24b | $0.33b |
| Tasmania | $0.24b | $0.06b | $0.05b |
| Offshore | $16.2b | $4.06b | — |
Figures are $ billion. All royalty today is every minerals and petroleum royalty the jurisdiction collects under the current system. Offshore has no current-system royalty because the Commonwealth collects it.
The offshore share is allocated by adjacent area: Western Australia $2.92 billion, the Northern Territory $0.57 billion, Victoria $0.41 billion and Queensland $0.08 billion. Nothing is given up against it, because no state collects a royalty on offshore production today.
On the levy alone every state is still behind. That is expected, and it is why the second half of the reform is not optional.
9.2 The Traditional Owner share
Two per cent of all REL revenue, approximately $2.07 billion a year, quarantined into the Traditional Owner Services Fund and paid automatically. It sits on top of whatever is agreed project by project, and is not to be taken into account in determining an agreement payment. It is a legislated entitlement, not a payment to be negotiated or a royalty to be disputed. Staged at 1 per cent for the first three years while delivery systems are built.
The fund pays for frontline delivery — health clinics, school facilities, housing maintenance, water infrastructure, aged care and community-determined priorities — administered by an Indigenous Australia Commission reporting directly to Parliament rather than to a minister, with spending published annually in full. The National Indigenous Australians Agency is abolished and its advisory function absorbed, so an administrative layer is removed rather than added. Design detail at Federal Platform §2.8.
Against the current position this is the largest proportional change in the model. Traditional Owners today receive under 1 per cent of the total public take through statutory arrangements, which exist in the Northern Territory and South Australia and nowhere else. What they receive under negotiated agreements is not published and cannot be measured — Memo 3 section 8.3 sets out the range and why it cannot be narrowed.
10. The GST reform, and why the states agree
Section 9.1 leaves every state behind on the levy. The reform that closes the gap is the second half of the package, and it has two parts.
The rate rises from 10 to 12 per cent, with every additional dollar going to the states. Fresh food and prescription medicine stay exempt, utilities become newly exempt, and consumption above $100,000 in a single transaction is surcharged at 30 per cent on the excess. The platform puts the net gain to the pool at approximately $10 billion a year, taking it from $95.1 billion to $105.1 billion.
The luxury tier sits outside that figure and outside the reconciliation below, which understates the state positions by roughly $2.5 billion in the first year.
And the distribution formula is replaced with a single rule: GST is returned to the state where it was spent. Horizontal fiscal equalisation (HFE) and the Commonwealth Grants Commission (CGC)'s role as distributor are abolished. Both revenue streams then follow the same principle — money returns to where it was generated, by arithmetic rather than assessment. The levy follows production; the GST follows consumption.
Under equalisation a state that raises royalty revenue is assessed as having greater fiscal capacity and its GST share falls accordingly, which is why rates have barely moved in decades while prices moved several hundred per cent.
10.1 The reconciliation
Figures are $ billion. The first three columns are what a jurisdiction receives or holds under each system; the net position is what it receives under the REL and the new GST rule, less what it collects in royalty today. Consumption share is proxied by population share, so the GST column is indicative.
| Jurisdiction | Levy share, own production | Levy share, offshore | All royalty today | Change in GST | Net position |
|---|---|---|---|---|---|
| New South Wales | 3.90 | 0.04 | 3.10 | 7.23 | +8.07 |
| Western Australia | 9.15 | 2.92 | 12.79 | 3.76 | +3.04 |
| Victoria | 0.33 | 0.41 | 0.19 | 0.82 | +1.37 |
| Queensland | 6.24 | 0.08 | 12.57 | 5.13 | −1.12 |
| Tasmania | 0.06 | 0.00 | 0.05 | −1.44 | −1.43 |
| South Australia | 0.30 | 0.04 | 0.52 | −1.88 | −2.06 |
| Northern Territory | 0.24 | 0.57 | 0.33 | −3.53 | −3.06 |
Figures are $ billion. All royalty today is every minerals and petroleum royalty the jurisdiction collects under the current system, which the REL replaces. Change in GST is the movement from replacing the distribution formula with the state where the money was spent.
Three of the four resource jurisdictions clear. New South Wales gains $8.1 billion, Western Australia $3.0 billion and Victoria $1.4 billion. New South Wales gains most in proportional terms because it holds a large coal base and a small royalty on it — the higher coal rate works entirely in its favour. Western Australia gains despite giving up the largest royalty in the country, because it hosts most of the offshore production — which is also where most of the enabling infrastructure was built.
Queensland cannot be fixed by the rate, and here is the arithmetic
Queensland lands at minus $1.12 billion. Raising the coal and gas rates improves its position each time, but the improvement is a fraction of the gap and the rate runs out before the gap closes.
The reason is structural and it can be stated in one line. Queensland today keeps 100 per cent of a royalty charging about 29 per cent of the value of its coal. Under the REL it keeps 25 per cent of whatever rate is set. For a quarter of the REL to match a whole royalty of 29 per cent, the REL would have to charge more than 100 per cent of the sale value. There is no rate that closes it.
| Coal effective rate | Levy raised in Queensland | Its 25% share | Queensland's net position |
|---|---|---|---|
| 34.2% | $22.5b | $5.62b | −$1.74b |
| 38.8% | $25.0b | $6.24b | −$1.12b |
| 50% | $29.7b | $7.42b | +$0.06b |
| 65% | $36.0b | $9.00b | +$1.64b |
The second row is the schedule proposed in section 7. Coal would have to be levied at around 50 per cent of sale value for Queensland to reach break-even on 2023–24 figures. Metallurgical coal at $200 a tonne costs roughly $100 to $130 a tonne to produce. A 50 per cent levy takes $100 before any other cost is met. The rate is not the instrument.
What the instruments actually are
The baseline year. Queensland's coal royalty ran $15.36 billion in 2022–23, $11.1 billion in 2023–24 and an estimated $5.4 billion in 2024–25. Against the 2024–25 figure Queensland finishes roughly $3.5 billion ahead on the schedule in section 7 without any further change. The reconciliation above uses 2023–24 because it is the last year with published actuals across every jurisdiction, but no settlement can rest on one year of a series that moves by two thirds.
Strike it against a multi-year average, and agree the average before the rate.
A higher state share on coal. If the state share were 30 per cent rather than 25 on coal production alone, Queensland clears at the section 7 rate. That breaks the single-percentage rule and needs to be argued on its merits, but it is arithmetically available where a higher rate is not.
Direct compensation, on the same basis as South Australia, Tasmania and the Northern Territory. Queensland's gap is of the same character as theirs — a jurisdiction that cannot be made whole by the formula — and the same answer applies: a legislated, costed, published payment rather than an adjustment to the rate that would close an industry.
10.2 The three that cannot be reached
South Australia, Tasmania and the Northern Territory each receive substantially more GST than their consumption would return, and each has a production base far too small to make up the difference. South Australia finishes $2.1 billion behind, Tasmania $1.4 billion and the Northern Territory $3.1 billion — approximately $6.6 billion a year between them. The Northern Territory's offshore share of $0.46 billion is the only one of the three that receives meaningful help from the REL.
Raising the GST rate does not solve it. The Northern Territory currently receives about 4.8 per cent of the national pool while holding about 0.95 per cent of the population; for it to hold its present distribution on a consumption share, the pool would have to reach roughly $479 billion. No achievable rate rise closes a gap of that shape.
That is a statement of what equalisation was actually doing. Those jurisdictions face genuine cost differentials — remote service delivery, small and dispersed populations, and in the Territory's case the cost of servicing Indigenous communities across 1.3 million square kilometres. The formula was covering those costs indirectly, which is why it grew so complex and why it has been contested every year of its existence.
The shortfall is met by direct Commonwealth funding: appropriated as a named line item, costed against the actual cost of delivering the services, published in the budget papers and reported annually to Parliament. Not a transition payment that tapers. Not a top-up negotiated each year. A standing appropriation that replaces what the formula was quietly doing, and does it visibly. The platform already argues exactly this for the Northern Territory; it has to be extended to South Australia and Tasmania and the amounts published.
This is the condition the package depends on. A change to the GST rate or base requires the unanimous agreement of every state and territory — there is no majority path and no Commonwealth override. Those three are each worse off on the GST change taken alone, so each holds a veto over the whole reform, including the REL, because it is the GST change that makes the REL acceptable to Western Australia and Queensland.
The $6.6 billion belongs in the costing from the first draft, not in a schedule appended to it.
10.3 How the amount is calculated
A payment of this size cannot be a number agreed at National Cabinet, or it becomes the negotiation the reform was meant to end. It has to be a formula in the Act, applied identically to all eight jurisdictions, with no special cases and nothing left to assessment.
The entitlement is the difference between what a jurisdiction received before the reform and what it receives after it. Baseline: its average total untied receipts — GST distribution plus all resource royalty — across a fixed run of financial years before commencement. New receipts: its consumption-share GST plus its 25 per cent levy share on its own production and its adjacent area. Where the baseline is higher, the difference is paid. Where it is not, nothing is paid.
Two features matter more than the arithmetic. The entitlement is indexed by population growth and a published price index — the mechanical form of costing it against the services it replaces, and the only form that cannot be re-litigated every year. And it is never reassessed against another jurisdiction's fiscal capacity. That single exclusion is what separates this from the system it replaces: the Grants Commission compared jurisdictions against each other annually, and that comparison is the thing being removed.
It is paid as a standing appropriation from the Commonwealth's share of the levy, published by jurisdiction and by year. The scale is manageable on the Commonwealth's own numbers: it moves from $34.0 billion to $75.7 billion, and the balancing payments are approximately $6.6 billion of that — under nine per cent of the new take, leaving it roughly $35 billion ahead.
The same formula reaches Queensland without a separate instrument. Its coal royalty ran $15.36 billion, then $11.1 billion, then approximately $5.4 billion; a baseline drawn across several years sits well below the single year its $1.1 billion shortfall is measured against, and most or all of that gap closes on the arithmetic rather than on a concession.
Two elements of this formula are deliberately left open. How many years the baseline window covers determines whether the boom years are counted, which moves money between Queensland and Western Australia on one side and the smaller jurisdictions on the other.
And whether the entitlement holds its level permanently or declines in real terms is a judgement about how long a jurisdiction should be held to a position it reached under a system that no longer exists. Both should be set by independent modelling and written into the Act, not settled between governments after it passes.
11. What the system delivers
Four parties are affected and each gets something the present arrangement does not give them.
11.1 For Australians
- Forty billion dollars a year more from resources the public already owns.
- A base that cannot be engineered. Sale value appears on an invoice. Profit is a calculation, and it moves.
- A take that rises with the price, instead of one that hands the whole of a boom to the shareholder.
- Gas and oil charged like everything else — worth $19 billion a year on its own.
- More projects, sooner. Australia holds orebodies undeveloped for decades on process rather than geology.
- Revenue that builds something. A resource extracted once funds an asset that operates for a century.
The second of those is the load-bearing one. The Petroleum Resource Rent Tax is the demonstration: a profit-based tax on one of the world's largest liquefied natural gas industries, collecting about $1.5 billion a year, because profit moves with depreciation schedules, financing, related-party fees, marketing hubs and the timing of capital expenditure. A levy on sale value has nothing to shift.
11.2 For the industry
- The rate is knowable thirty years out, from public information.
- The calculation is trivial — tonnes sold, price at sale, four bands, no deductions.
- Downside protection through the floor band. No existing royalty offers it.
- One rulebook, not eight. Same definition of value, same bands, same reporting in every jurisdiction.
- The offshore boundary disappears. No more paying under two regimes on two bases.
The first is worth more than it sounds. Australian resource projects carry a regulatory risk premium in the discount rate, because eight governments can change eight sets of rules at any time and periodically do. Removing that premium raises project net present value, and where the gain exceeds the additional levy the higher known rate is cheaper than the lower uncertain one — on the producer's own numbers.
The second is worth $20 to $50 million a year to a large project, which is what royalty compliance across three incompatible systems currently costs before a dollar reaches a government or a community.
A further mechanism is proposed separately: a defined portion of the REL paid is designated as the producer's equity in the Sovereign Build Corporation (SBC), giving the industry an ownership stake in the corridor, power and freight infrastructure the REL builds — infrastructure those same producers use. It is summarised in the platform and will be set out in a subsequent memo.
11.3 For the states and territories
The equalisation clawback ends. Today a state that raises its royalty is assessed as having greater fiscal capacity and loses GST share for it — it wears the whole fight with the industry and keeps a fraction of the money. That is why rates have barely moved in decades while prices moved several hundred per cent. Under the reform the REL follows production, the GST follows consumption, and neither is assessed.
The race to the bottom ends. States presently compete on rate to attract projects — South Australia's 2 per cent new mine rate is an explicit instance. One national schedule removes the instrument, so no jurisdiction can be undercut and none has to undercut.
And states get a reason to want development again. This is the change with the largest practical effect and the least obvious mechanism.
Consider an offshore gas project today. The state hosting it provides the industrial land, the port, the road and power upgrades, the workforce housing and the planning approvals. It absorbs the environmental argument and the local political cost. And it collects nothing from the resource, because the resource is Commonwealth.
Whatever payroll tax flows back is then assessed by the Grants Commission and much of it clawed out of its GST share. A state premier looking at that arrangement has no fiscal reason to champion the project and several political reasons not to.
The same logic runs onshore. A state that approves a new mine raises its royalty revenue, is assessed as having greater fiscal capacity, and loses GST accordingly. Development is fiscally punished at the margin. That is not a theory about incentives — it is the arrangement Australian states have operated under for two decades, and it shows in how long approvals take.
Under this model a state receives 25 per cent of the REL raised on production in its own ground and in its own adjacent area, and keeps its GST because the GST follows consumption rather than assessed capacity. Every project that proceeds makes the state better off, and nothing is taken back.
States move from indifferent or obstructive to actively invested — and states control the things that actually determine whether a project gets built: planning, ports, industrial land, environmental approval, road and power access, and the workforce that lives near it.
Revenue becomes predictable in shape. The formula is legislated, not renegotiated each budget, and it is not available as leverage. And the discipline that base-band revenue funds recurrent spending while the bands above it go to a sovereign fund is what stops a boom creating commitments a bust cannot carry — Queensland went from $15.36 billion to an estimated $5.49 billion in two years.
11.4 For Traditional Owners
- Paid automatically — approximately $2.07 billion a year, against $200 to $400 million in statutory entitlements today, and on top of whatever is negotiated.
- Not contingent on a negotiation, a confidential agreement, or the solvency of an operator.
- Visible — published by community, administered by a body reporting to Parliament rather than to a minister, with a mandatory distribution floor.
And it ends the reason for delay. A native title party cannot be awarded a payment based on extraction value at arbitration, and generally cannot fund its own negotiation. Time is therefore the only leverage the statute leaves, which is why major agreements take years and projects sit on approved geology and unapproved access. Paying the share by statute removes the reason to spend years extracting it — which is why this does more for approval timeframes than any process reform.
11.5 For new projects
The largest benefit to a developer is not the rate. It is that almost everything a project currently has to negotiate becomes something it can look up.
- No royalty to negotiate. It is published, so a proponent and its financiers can price it before the first meeting.
- No negotiation over the Traditional Owner payment. It is legislated.
- Approvals on a six-month statutory clock, with the reviews running concurrently and a deemed decision if it expires.
- One jurisdiction, not three. One levy, one calculation, one payment, one portal.
- No advantage in structuring — nothing gained by routing through a particular state, entity or marketing hub.
- The state government becomes an ally rather than an obstacle, for the reason set out at 11.3.
- The infrastructure follows — corridor, power, water and freight built to the mine gate.
The second item matters more than its length suggests. Removing the money from a land access negotiation leaves heritage protection, employment, contracting and environmental management on the table — which is what such an agreement should be about, and which settles far more quickly once the payment is not in dispute.
The last matters in remote provinces. A proponent there currently prices its own road, its own power and its own port access into the capital cost, and many projects fail on that arithmetic rather than on the orebody.
11.7 Nobody gains from a low price
The most valuable property of this design is not an anti-avoidance rule. It is that the reason to cheat disappears.
Consider the arrangement the current system produces. An Australian producer sells to its own marketing arm in Singapore at a low price. The Singapore arm on-sells at the market price. The margin between them is earned in a jurisdiction that taxes it lightly, and Australia collects on the low number.
Shell's Singapore trading arm made billions of dollars in profit this way over the eight years to 2024. BHP and Rio Tinto ran the same structure from the mid-2000s, and both changed it only after the Australian Taxation Office pursued them and they settled.
That arrangement exists because Australia taxes profit at the extraction stage. Move margin offshore and the profit follows it. The REL removes company tax from extraction and charges on sale value instead, so there is no Australian profit at that stage to move. The hub may keep operating for treasury and logistics reasons. It has nothing left to do on tax.
Then the incentive reverses. The levy is fixed by the published benchmark and the assayed grade, not by the number on the producer's own invoice. It is the same whether the cargo is invoiced at $8 or $14 — which means every additional dollar of realised price belongs to the producer. Selling low to a related party now costs the seller money and saves no tax at all. Under-pricing stops being profitable and becomes merely pointless.
The marginal structure keeps that true at every price. Even in coal's peak band the producer retains 35 cents in each additional dollar, so revenue to the producer never falls as the price rises. There is no point on the schedule at which anyone is better off with a lower price. A whole-of-price structure fails this test, which is the reason it was rejected in section 4.
The result is an alignment that does not exist anywhere in the present arrangements. The Commonwealth, the state the ore came from, Traditional Owners and the producer all do better when the price is higher. Nobody at the table is arguing for a lower number.
Two incentives do survive, and they are named here rather than left to be discovered. Grade still matters, because the benchmark is selected by grade — which is why the assay is taken independently at loading rather than read off the contract.
The downstream boundary still matters too, because margin moved past the first-sale point is taxed normally rather than levied, so a vertically integrated producer has a reason to argue that extraction ended earlier and cheaper than it did. That is why section 3 requires the boundary to be defined on the face of the Act.
11.6 What it is not
It is not a tax on mining. It is the price of an asset the public owns, charged at a rate that moves with what the asset is worth, replacing a tax that was never a good instrument for the job.
It is not novel. Queensland has run price-stepped coal royalties since 2022 and a price-tiered gas royalty since 2020. The Northern Territory rebuilt its whole mineral royalty in 2024. What is proposed is that the rest of the country adopt what already works.
12. Summary
Queensland charges its coal and its gas on a price-stepped schedule. Both were introduced against industry opposition, both are still in place, and together they collect more than five other jurisdictions combined. This proposal takes that design national.
One levy — the REL — on the sale value of the ore, at marginal rates set per commodity and stepped by the market price at the time of sale. No deductions. Applied at first arm's-length sale. The same schedule onshore and offshore, so the Commonwealth boundary stops splitting one industry across two systems. Replacing the state royalty, the Petroleum Resource Rent Tax and company tax on extraction — not added to them.
One system, and it divides what it collects. The same levy funds three parties at the point of collection: 73 per cent to the Commonwealth, 25 per cent to the state or territory the ore came from, and 2 per cent to Traditional Owners. Divided by a formula in the Act rather than negotiated between them afterwards.
Today those parties collect separately, through different instruments, on different bases, and argue about the result every year. That is the change: not simply a higher charge, but a single charge with the division built into it.
The largest single correction is gas and oil, which return about 4.7 per cent of their value to the public today against 7.5 per cent for iron ore and above 20 per cent for Queensland coal. Charging gas properly raises $22.0 billion against roughly $3 billion now, and no state loses anything in the transaction.
At the illustrative rates in section 7 it collects $103.7 billion a year, against $63.9 billion today — counting every resource royalty, the PRRT and company tax on extraction. That is 25.4 per cent of the sale value it applies to, and 52 per cent of industry earnings before royalty and tax, up from 32 per cent. The industry retains $95 billion against $135 billion now.
The Commonwealth receives $75.7 billion against $34.0 billion today. The states receive $25.9 billion against $26.9 billion in royalty — their own production plus their adjacent area offshore — and are made whole by the GST reform: New South Wales ahead $8.1 billion, Western Australia $3.0 billion, Victoria $1.4 billion.
Queensland finishes $1.1 billion behind on 2023–24 figures and ahead on 2024–25 ones, which is why the settlement has to be struck against a multi-year average rather than a single year. Traditional Owners receive $2.07 billion against $200 to $400 million in statutory entitlements today, paid automatically rather than negotiated, and on top of the agreement payments that continue unchanged.
Three things in this are not yet settled. The commodity rates are illustrative and need modelling against each cost curve. The band thresholds within them need the same. And South Australia, Tasmania and the Northern Territory finish approximately $6.6 billion behind on the GST change — a shortfall no levy percentage can close, which is met by the balancing entitlement at 10.3, paid from the Commonwealth's share of the levy and costed and published alongside the REL rather than after it.
Those three hold a veto over any change to the GST rate or base, so that funding is a condition of the reform passing, not a refinement to be settled later.
A first-principles statement of direction rather than a ready-to-implement blueprint. It sets four things: a higher public return on an asset the public already owns, one instrument in place of eight, a charge that rises with the price and falls with it, and a legislated Traditional Owner share. The rates, the band thresholds and the settlements with the smaller jurisdictions are modelling and drafting work, and are identified as unfinished wherever they appear.
13. Sources
- RevenueWA and the Western Australian Department of Mines, Petroleum and Exploration, Mining (Royalties) Regulations 2025 — the 7.5 per cent bulk ore rate used in the total-take comparison in section 5, and the practice of converting United States dollar shipments at a published Reserve Bank quarterly rate, cited in section 4.
- Queensland Revenue Office, Mineral Resources (Royalty) Regulation 2025 — the six marginal coal tiers, and the structure on which the marginal band design in section 3 is modelled.
- Queensland Treasury, budget papers and mid-year fiscal and economic review — coal royalty collections of $15.36 billion in 2022–23 falling to an estimated $5.49 billion in 2024–25, cited in section 8 on the treatment of cyclical revenue.
- Institute for Energy Economics and Financial Analysis (2025) — the average effective rate on Queensland coal prices in 2024 of approximately 20 per cent against the 40 per cent top tier, and the observation that coal below $150 a tonne is taxed as it was before the tiers were introduced.
- Australian Government, Petroleum Resource Rent Tax Assessment Act 1987 and Petroleum Resource Rent Tax Act 1987 — the profit-based structure, the uplift on undeducted expenditure, and the deduction rules described in section 1.
- Australian Government, Minerals Resource Rent Tax Act 2012 and Minerals Resource Rent Tax Repeal and Other Measures Act 2014 — the crediting of state royalties against the federal tax, the resulting collection failure, and the 2014 repeal.
- Northern Territory Department of Treasury and Finance, Mineral Royalties Act 2024 — the four-category processing ladder referred to in the schedule design, and the Territory's 2024 move from a profit-based to an ad valorem base.
- Resources Victoria, royalty information sheets under the Mineral Resources (Sustainable Development) (Mineral Industries) Regulations 2019 — the definition of net market value, which permits deduction of directly incurred selling costs and is the contrast case for the no-deductions rule proposed in section 2.
- OECD, Pillar Two model rules on the global minimum tax — the treatment of royalties as generally outside the definition of covered taxes, and the top-up mechanism described in section 9.
- Geoscience Australia, Australia's Energy Commodity Resources, and the Department of Industry, Science and Resources Resources and Energy Quarterly — the share of oil, condensate and liquefied natural gas production drawn from offshore fields in the Northern Carnarvon, Browse and Bonaparte basins, against Queensland's onshore coal seam gas; used to split the levy base at section 8.1.
- Queensland Revenue Office, Petroleum and Gas (Royalty) Regulation 2021 part 2 division 3 — Queensland's volume-based petroleum royalty with a tiered rate set by the average sales price or published benchmark, replacing the 12.5 per cent wellhead-value model from 1 October 2020; cited in section 7.1 as an existing Australian precedent for a price-tiered resource charge.
- Australian Government, Offshore Petroleum and Greenhouse Gas Storage Act 2006 — the division of Commonwealth waters into an adjacent area for each state and the Northern Territory, against which offshore titles are already administered and the joint authorities constituted; the boundary used to allocate the offshore state share in section 8.1.
- Australian National Audit Office, Collection of North West Shelf Royalty Revenue, and the Commonwealth Grants Commission assessment methodology — the sharing of North West Shelf royalty between the Commonwealth and Western Australia, and the grants paid to Western Australia in lieu; used in the current-system column at sections 8.1 and 9.1.
- Commonwealth Grants Commission, GST Relativities 2025–26 and the March 2026 update — GST distribution by state for 2024–25 and 2025–26, the $95.1 billion pool, the 0.75 relativity floor and the no-worse-off payments; used in the section 10.1 reconciliation.
- Australian Bureau of Statistics, National, state and territory population — the population shares used to proxy consumption shares in the spend-based GST column at section 10.1.
- Sovereign Australia Party, What Australia Charges For Its Resources (Memo 3, 2026) — the jurisdictional detail, current royalty rates and revenue composition on which this proposal is built.
- Sovereign Australia Party, The Australian New Deal, Federal Platform — "The Distribution Model — 73 / 25 / 2" and the GST distribution reform: the Commonwealth collecting 100 per cent of the REL nationally and distributing by legislated formula; the state share drawn from production in that jurisdiction; GST returned to the state where it was spent with horizontal fiscal equalisation and the Commonwealth Grants Commission's distributor role abolished; remote and Indigenous service delivery funded directly by the Commonwealth as a national obligation rather than through the distribution formula; the platform's 85 / 15 extraction-and-population weighting, noted at section 9.1 as inconsistent with the production rule; Productivity Commission review every five years with the formula alterable only by Parliament; the Traditional Owner Services Fund administered by an Indigenous Australia Commission reporting to Parliament, with the National Indigenous Australians Agency abolished; and the estimate that a large project spends $20 to $50 million a year on royalty compliance administration. Cited throughout section 8.
- Sovereign Australia Party, The Australian New Deal, Federal Platform — the six-month statutory maximum for federal mine approvals with concurrent environmental, native title and financial assurance review; cited in section 11.5.
- Sovereign Australia Party, The Australian New Deal, Federal Platform §2.8 — the Traditional Owner Services Fund and the legislated share referred to in section 8.
- Centre for International Corporate Tax Accountability and Research, reporting on Shell's Singapore liquefied natural gas trading arm (2026) — billions of dollars in profit over the eight years to 2024 from buying LNG from producer countries including Australia and on-selling at a mark-up, and the comparable Singapore marketing hubs established by BHP and Rio Tinto from the mid-2000s and modified only after Australian Taxation Office action and settlement; cited in section 11.7.
- Australian Taxation Office, settlement announcement on offshore procurement hubs — the $157 million settlement with Ampol Limited over a Singapore procurement hub, and the ATO's stated focus on offshore hubs as a profit-shifting mechanism; cited in section 11.7.