Capricorn Energy plc said that the floating production storage and offloading (FPSO) facility had arrived for the Sangomar oil field development, offshore Senegal.
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The FPSO set sail from Singapore in December 2023 while operator Woodside Energy plc still targets first production for mid-2024.
Capricorn added it maintained it owned no registration duty after it sold its entire project interest in 2020 to Woodside.
Woodside subsequently received notice from the Senegalese Tax Authority that Capricorn should have paid registration duty of $28.2 million on the transfer to Woodside.
Following November’s tax notice, Capricorn stated last month that the authority had agreed that real estate capital gains tax was not payable if a taxable gain had not been made.
“However, the Senegalese Tax Authority has not yet adjusted its claim to consider Capricorn’s historic base costs to recognise that Capricorn incurred a capital loss on its sale of its interests in the Sangomar field to Woodside,” said Capricorn in its statement today.
“Meanwhile, the tax process continues with respect to the matter of Senegalese registration duty ($25m plus interest and penalties).
“Capricorn’s position remains that no Senegalese registration duty is payable.
“The Senegalese tax authorities had previously confirmed in writing to Capricorn that transactions prior to first oil would not be subject to registration duties.
“Accordingly, the Company will continue to vigorously defend its position on this matter.”
The company “remains committed” to returning any proceeds of the contingent payment to its shareholders.