This is an incredible situation for a nationwide network of services stations as well as a large refinery which makes up the "downstream" division of the global oil brand.
Shell last year sold its downstream business in Australia including its Geelong refinery, a portfolio of 870 petrol stations and other assets to Dutch oil group Vitol.
The company which owns the business now is called Viva Energy Australia but it has kept the Shell branding on the service stations.
Shell held onto its jet fuel business as well its "upstream" oil and gas fields.
This Fairfax Media analysis will take the reader right through Shell's businesses, former and current, using accounts and recently lodged submissions to a Senate inquiry on tax evasion to ask the question: are we getting pumped?
Shell's reported revenues for its downstream business in the two years leading up to the deal with Vitol were $21.7 billion (in the 2013 financial year) and $22 billion (in 2012) . Yet its accounts show it paid no company tax in those years (actually receiving a refund in 2012)
In total, cash receipts from customers were almost $50 billion for the two years. At the same time tax benefits were recorded of $38 million (in 2013) and $111 million (in 2012) respectively.
It is difficult to be precise about this most recent year because a full financial picture is not available.
The deal with Vitol is also complicated. It appears to have been structured offshore in conjunction with a local franchise deal which could lessen the tax paid for the parties.
Further complicating comparisons is the fact that Shell has not produced stand-alone accounts for the seven-and-a-half months before the assets were sold to Vitol.
However accounts show that, in broad terms, the performance of Shell's downstream business altered little after it was sold.
Viva's revenues for the four-and-a-half months it has owned Shell downstream amount to $6.2 billion.
Against that revenue the Viva accounts show an income tax benefit of $18.4 million. It also availed itself of tax deductions for research and development.
So assuming all things were similar to last year this vast petrol refining and service station operation may have paid no tax despite something like $60 billion in revenues in three years.
It is true that petrol refining and retailing are high-volume low-margin businesses. Shell and its peers cannot be expected to make a profit every year.
Yet it is also true that the scope for transfer pricing is high as it purchases billions in product from related companies every year in Singapore and, bottom line, this enormous business – across now two owners – appears to pay no income tax in Australia.
Senate takes aim
So it is that the Senate committee investigating corporate tax avoidance now has the oil majors in its sights.
Chevron is now locked in court skirmishes with the ATO and is arguably a worse offender on the tax front than Shell – based on what we know about what the tax office says is a sham transaction. Executives from Shell, Chevron, BP and ExxonMobil have been summonsed for hearings later in the month.
The oil majors have now lodged their submissions with the Senate. While BP has elected to disclose its income tax paid, which is a good thing as income tax and its avoidance is the subject of the inquiry, others have not been so forthcoming.
Instead they have followed the example of the United States digital giants in the first hearings earlier this year and talked about GST, payroll taxes and petrol excise and their contribution to the economy through jobs and so forth. "Nothing to see here" probably nails it as a summary of their position.
The Viva Energy submission was signed by chief executive Scott Wyatt who uses his correct Australian legal entity title, not some cross border, global or regional title like we see with Google's Australian branch operations
It is interesting that unlike most Australian subsidiaries of multinationals, Viva actually borrows its money from a consortium of third party banks, giving it less scope to avoid tax.