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Oil Taxation Manual
Publication Date: 2025
Publisher: Bloomsbury Professional
Copyright: 2025 Crown
Oil Taxation Manual
An overview of the law and practice for the oil fiscal regime, in particular Petroleum Revenue Tax, ring fence Corporation Tax and the supplementary charge
Last update: 31st January 2025
Contents
- OT00002: Introduction
- Close sectionOT00005: The Taxation of the Oil Industry - overview: contents
- OT00010: Background
- OT00020: The Current Fiscal Regime for Oil and Gas
- OT00030: Interaction between the Elements of the Fiscal Regime
- OT00040: Legal Overview 1918 to Petroleum Act 1998
- OT00100: Early Activity in the North Sea
- OT00110: Public Accounts Committee Report 1973 and the 1974 White Paper
- OT00150: Oil Taxation Act 1975
- OT00190: Other Developments to the Fiscal Regime 1975 to 2014
- OT00500: Map of new and old legislative references following 2009 and 2010 consolidation acts
- Close sectionOT01000: The NSTA role in the UK North Sea: contents
- Close sectionOT02000: Oil Industry Accounting: contents
- OT02001: Introduction
- OT02002: Unique Features of the Oil & Gas Industry
- OT02003: Generally Accepted Accounting Practice
- OT02020: Companies Act 2006 and use and application of accounting standards in the UK
- OT02030: IFRS 6 - Exploration for and Evaluation of Mineral Resources
- OT02085: Successful Efforts and Full Cost Accounting Methods
- OT02110: Joint Venture Accounting - Introduction.
- OT02115: Joint Venture Accounting - FRS 102
- OT02116: Joint Venture Accounting - FRS 102 - Summary of the nature of relationships and accounting treatment
- OT02120: Joint Venture Accounting - IFRS
- OT02121: Joint Venture Accounting: IFRS : Summary of the nature of relationships and accounting treatment
- OT02190: Underlift and Overlift
- OT02195: Decommissioning
- OT02200: Disclosure of Commercial Reserve Quantities.
- Close sectionOT03000: Petroleum Revenue Tax: contents
- Close sectionOT03005: Introduction to PRT: overview: contents
- Close sectionOT03500: PRT: Changes - FA93: contents
- OT03510: Outline
- OT03515: Abolition of PRT-Taxable and Non-taxable Fields
- OT03520: Other consequences of abolition - Non-field expenditure
- OT03525: Reduction in Rate of PRT and Interest Cap
- OT03530: Apportionment of expenditure between taxable and non-taxable fields
- OT03535: Fixed assets and dedicated mobile assets - attribution of income and expenditure
- OT03540: Non-dedicated mobile assets
- OT03545: Abolition and Tariffs
- OT03550: Abolition and TRA
- Close sectionOT04000: PRT: Administration: contents
- OT04005: Chargeable Periods,
- OT04030: Appointment of Responsible Person
- OT04060: Returns by Responsible Person PRT 2
- OT04090: Returns by Participators PRT 1
- OT04095: Returns by Participators: PRT 1A
- OT04100: Returns by Participators: PRT 6
- OT04120: Deferral of Returns
- OT04150: Payment Provisions: Payments on Account: PRT 6
- OT04180: Payment on account
- OT04210: Payment Provisions: Instalments
- OT04240: Payment Provisions: Payment of Tax
- OT04270: Payment Provisions: Interest
- OT04280: Payment Provisions: Interest Cap
- OT04300: Assessments and Loss Determinations
- OT04330: Amended Assessments and Loss Determinations
- OT04360: Appeals against Assessments
- OT04390: Claims Outline
- OT04395: Claims: Schedule 5 / Schedule 7 Interface
- OT04400: Claims: Time Limits
- OT04410: Claims: Claim Periods
- OT04420: Claims By Responsible Person: PRT 30
- OT04425: Responsible Person Claims: Division of Expenditure
- OT04450: Responsible Person Claims: Confidentiality
- OT04480: Claims by Participators: PRT40
- OT04510: Schedule 7 Claims PRTD8 & PRT60B
- OT04540: Schedule 8 Claims
- OT04570: Cross Field Allowance Elections
- OT04600: Deficient Claims
- OT04630: Decisions And Allowance Of Claims
- OT04635: Decisions: Part and Final Claim Decisions
- OT04640: Decisions: Reservations on Claims
- OT04643: Decisions: Claim Period in Dispute
- OT04645: Decisions: Time Limit for Final Claim Decision
- OT04650: Decisions: Timing of Claim Decisions
- OT04660: Claims and Correspondence during the assessing rounds
- OT04690: Appeals against Claim Decisions
- OT04693: Appeals against Claim Decisions: Date of Receipt of Appeal
- OT04696: Appeals against Claim Decisions: Part and Final Decisions
- OT04699: Appeals against Claim Decisions: Late Appeals
- OT04702: Appeals against Claim Decisions: Effect of Appeal on PRT Payable
- OT04705: Appeals against Claim Decisions: Determination of Appeal by Agreement
- OT04708: Appeals against Claim Decisions: Abandonment of Appeal
- OT04711: Appeals against Claim Decisions: Review by Another Officer
- OT04714: Appeals against Claim Decisions: Varying of Decisions
- OT04717: Appeals against Claim Decisions: Appeal to the Upper Tribunal
- OT04720: Negative Claims
- OT04740: Informal Claims
- OT04743: Informal Claims: Procedures
- OT04746: Informal Claims: Research Expenditure
- OT04750: Notices Of Variation
- OT04780: Withdrawal Of Claims
- OT04785: relief for overpaid tax
- OT04790: Information Powers
- OT04795: Information Powers: Documents and Particulars
- Close sectionOT05000: PRT: Valuation: contents
- OT05004: PRT: Computation: contents
- OT05200: PRT: The Nomination Scheme: contents
- OT05300: PRT: Valuation of Non Arm's Length Disposals and Appropriations - Oil: contents
- OT05360: PRT: Valuation of Non Arm's Length Disposals and Appropriations - Gas: contents
- OT05600: PRT: Commingling: contents
- OT05700: PRT: Advanced Petroleum Revenue Tax
- OT05705: PRT: Supplementary Petroleum Duty
- OT05800: PRT: Attribution of Blended Crude Oil - Terminals Liftings: contents
- Close sectionOT08900: PRT: Expenditure, Allowances and Reliefs: contents
- OT09000: PRT: Allowable Field Expenditure: contents
- OT10000: PRT: Decommissioning: contents
- OT10800: PRT: Decommissioning certainty: contents
- OT11000: PRT: Long Term Assets: contents
- OT12000: PRT: Supplement: contents
- OT13000: PRT: Cross Field Allowances: contents
- OT13100: PRT: Spreading Elections: contents
- OT13200: PRT: Exempt Gas provisions: contents
- OT13450: PRT: Transmedian Fields
- OT13500: PRT: Foreign Fields: contents
- OT13750: PRT: Non Field Expenditure: contents
- OT14250: PRT: Provisional Expenditure Allowance: contents
- OT14500: PRT: Expenditure Incurred: contents
- OT14600: PRT: Associated Party Transactions: contents
- Close sectionOT15000: PRT: Tariff and Disposal Receipts: contents
- OT15010: Outline
- OT15025: Definition Of Tariff Receipts
- OT15060: Definition Of Disposal Receipts
- OT15100: Definition Of Qualifying Asset
- OT15150: Chargeable Field
- OT15180: Valuing The Consideration
- OT15210: Participators In Common
- OT15240: Cessation of Field or Tariff Use
- OT15250: Reduction of Disposal Receipts For Tax-Exempt Tariffing Use
- OT15300: Restriction of Supplement on Disposal
- OT15350: Insurance Receipts
- OT15400: Consideration Received by Connected Persons under Avoidance Schemes
- OT15450: Transactions not At Arm's Length
- OT15500: Use by Connected or Associated Person under Avoidance Schemes
- OT15540: Purchase at Place of Extraction
- OT15580: Definition of Connected Person
- OT15600: Tariff Receipts Allowance
- OT15625: Definition of a User Field
- OT15650: Qualifying Tariff Receipts
- OT15675: Calculation of Participator's Share of Tariff Receipts Allowance
- OT15700: Calculation of Tariff Receipts Allowance relating to only part of Throughput
- OT15725: Calculation of Tariff Receipts Allowance: Participators in Common
- OT15750: Qualifying Tariff Receipts referable to Different Periods
- OT15770: Qualifying Tariff Receipts referable to Different Periods - Example 2
- Close sectionOT15800: PRT: Tax-Exempt Tariffing Receipts: contents
- OT15810: Outline
- OT15820: Definition
- OT15830: Definition of New and Existing Fields
- OT15840: Foreign Fields
- OT15850: Transmedian Fields
- OT15860: Definition of Qualifying Existing Field
- OT15870: Excepted Assets - Assets Wholly Situated in Existing Field
- OT15880: Excepted Assets - Tankers and Tanker Loaded Fields
- OT15890: Excepted Assets - Excess Capacity Election
- OT15900: Transitional Provision
- OT15905: Operation of Transitional Provisions
- OT15910: Tax-Exempt Tariffing Receipts - Related Expenditure
- OT15920: Cost allocation - Modified Approach
- OT15925: Cost allocation - Application of the Modified Approach
- OT15930: Participators in Common and Connected Person Transactions
- OT15940: Cost allocation - Calculation
- Close sectionOT16000: PRT: Allowable Losses: contents
- OT16050: Outline
- OT16100: Set off against Preceding Periods
- OT16150: Set off against Future Periods
- OT16200: Set off when Production Ceases
- OT16250: Unrelievable Field Losses
- OT16260: Unrelievable Field Losses - Link to Chargeable Periods
- OT16270: Unrelievable Field Losses - Associated Party Claims
- OT16280: Unrelievable Field Losses - Acquisition of Interests in Producing Fields
- OT16290: Unrelievable Field Losses - Unrelated Field Expenditure
- OT16300: Unrelievable Field Loss: Procedures
- OT16350: Unrelievable Field Losses - Permanent Cessation of Winning Oil
- OT16400: Unrelievable Field Losses: Permanent Cessation of Production but Further PRT Assessable Income
- OT16450: Transfer of Licence Interests
- OT16500: Unrelievable Field Losses: Licence Transfers: Anti-Avoidance - Background
- OT16510: Unrelievable Field Losses: Licence Transfers - Anti-Avoidance - Details
- OT16520: Unrelievable Field Losses: Licence Transfers - Anti-Avoidance - Examples
- OT16550: Stranded Losses
- OT16600: Repayment Interest
- Close sectionOT17000: PRT: Oil Allowance: contents
- Close sectionOT17500: PRT: Safeguard: contents
- OT17525: Outline
- OT17550: Basic Calculation
- OT17560: Adjusted Profit
- OT17570: Accumulated Capital Expenditure
- OT17580: Example
- OT17590: Interaction with Spreading Elections
- OT17600: Limit on Chargeable Periods
- OT17650: Expenditure Allowed on Appeal, Late or Reclassified
- OT17700: Supplement in Safeguard
- OT17750: Deferred Expenditure Claims
- OT17760: Example 1
- OT17770: Example 2
- OT17780: Example 3
- Close sectionOT18000: PRT: Licence Transfers: contents
- OT18020: Outline
- OT18030: Procedures
- OT18040: Unused Expenditure Relief
- OT18050: Unused Losses
- OT18060: Accumulated Capital Expenditure (or Safeguard Capital Base)
- OT18070: Exempt Gas
- OT18080: Successive Transfers
- OT18090: Provisional Expenditure Allowance
- OT18100: Royalty Payments
- OT18110: Payments on Account
- OT18120: Surrender of New Participator's Loss
- OT18130: Terminal Losses accruing in chargeable periods ending after 17 March 2004
- OT18131: Terminal Losses - Example 1
- OT18132: Terminal Losses - Example 2
- OT18133: Terminal Losses - Example 3
- OT18135: Terminal losses accruing in chargeable periods ending before 17 March 2004
- OT18140: Non-Field Expenditure
- OT18150: Oil Allowance
- OT18160: Long-Term Asset Disposals
- OT18170: Transfers of Oil
- OT18180: Treatment of Overriding Royalty
- OT18190: Net Profit Period
- OT18200: Participation Rights
- Close sectionOT18250: PRT: Unitisations and Redeterminations: contents
- OT18260: Regulations
- OT18270: Unitisation Agreements
- OT18280: Unitisations - PRT Treatment
- OT18290: Re-determinations - Tax Consequences
- OT18300: Re-determination Claims
- OT18310: Negative Uplift and Safeguard
- OT18320: Farm Outs - Outline
- OT18330: Purchase of Licence Interests - No PRT field yet determined
- OT18340: Purchase of Licence Interests - PRT field determined and comprised in licence
- OT18350: Work Programme - PRT Treatment
- OT18360: Development Carry
- OT18370: Carried Interest - PRT Treatment
- Close sectionOT18500: PRT: Compliance: contents
- OT18510: Risk Factors and Distinctive Features of the Tax
- OT18520: Changes in Approach to the Management of Risk
- OT18530: LBS Operating Model: -The Role of the CRM in PRT
- OT18540: Tax Compliance Risk Management Process Guidance
- OT18550: The new approach to governance and delivery
- OT18560: The Relationship with Low Risk Customers
- OT18570: Responding to Specific Returns, Claims and Notification from a Low Risk Customer
- OT18580: Joint Venture Claims - Confidentiality
- OT18590: PRT Compliance: Clear Errors
- OT18600: Risk Assessment - Evaluating potential sources of risk against all available information
- OT18610: Risk Assessment - The Process
- OT18620: Risk Assessment - Mandatory Work, Projects and Campaigns
- OT18630: Risk Assessment - Regime Integrity Work
- OT18640: Risk Assessment - The Risk Review Process
- OT18650: Risk Assessment - First Claims and Continuing Audits
- OT18660: Risk Working - PRT / Accounts Reconciliations
- OT18670: Risk Working - Time Limits and Expenditure Claims
- Close sectionOT18750: PRT: Penalties: contents
- Close sectionOT19000: PRT: Appendices: contents
- Close sectionOT20200: Corporation Tax General: contents
- OT20201: Background
- OT20202: Overview of the Main Types of Costs Incurred in Oil Exploration and Production: Introduction
- OT20203: Overview of the Main Types of Costs Incurred in Oil Exploration and Production: Exploration
- OT20204: Overview of the Main Types of Costs Incurred in Oil Exploration and Production: Production
- OT20205: Overview of the Main Types of Costs Incurred in Oil Exploration and Production: Decommissioning and Abandonment
- OT20206: Payments under Licences.
- OT20250: Commencement of trade
- OT20251: World-wide Activities
- OT20252: Sale of a small quantity of oil
- OT20254: Link with mining
- OT20255: Cessation of trade
- OT20300: Take or Pay Gas Sales Contracts
- OT20310: Intangible fixed assets - Oil licences
- OT20315: Intangible fixed assets - Oil Licences - Exclusion from the scheme
- OT20400: EU Emissions trading scheme - Introduction
- OT20405: EU Emissions trading scheme - Phase I
- OT20410: EU Emissions trading scheme - Phase II
- OT20415: EU Emissions trading scheme - Phases III and IV
- Close sectionOT21000: Corporation Tax Ring Fence: contents
- OT21001: Introduction to the Ring Fence
- OT21002: Oil Extraction as a Separate Trade
- OT21003: Definitions of Oil Extraction Activities
- OT21004: Definitions of Oil Rights
- OT21005: Definition of Oil
- OT21006: The Practical Scope of the Ring Fence
- OT21010: Associated Companies
- OT21015: Delivery Outwith the UK
- OT21017: Definitions of Ring Fence Income and Ring Fence Profits
- OT21020: Separate Notional Ring Fence and Non-Ring Fence Trades
- OT21021: The Extension of the Ring Fence Extension Beyond Trading Income
- OT21023: Interest Received by ring fence companies
- OT21025: Unitisation and Re-determination Interest
- OT21026: The valuation of oil: contents
- OT21033: Seismic Survey Data
- OT21035: Other income
- OT21040: Tariff Receipts and Tax-Exempt Tariffing Receipts
- OT21045: Losses and group relief: contents
- OT21070: Expenses of management
- OT21071: Expenses of management - Transitional Provisions
- OT21075: Deduction of PRT in computing income for CT purposes
- OT21076: The treatment of repayments of PRT arising from the carry back of PRT losses
- OT21077: The treatment of repayments of PRT
- OT21078: The treatment of interest paid on repayments of PRT
- OT21080: PRT Paid by Foreign Field Participators
- OT21083: Sale and leaseback of assets
- OT21090: Currency differences and valuation of oil - Introduction
- OT21095: Currency differences and valuation of oil - the basis used for conversion
- OT21097: Currency differences and valuation of oil - Possible scenarios
- OT21100: The treatment of ACT
- OT21105: Transfer Pricing: contents
- OT21140: Advance pricing agreements
- OT21195: The Supplementary Charge: contents
- OT21240: First year allowances for a ring fence trade - contents
- OT21300: The Payment of Ring Fence CT and the Supplementary Charge in Three Instalments
- OT21400: Field Allowance: contents
- OT21500: Onshore Allowance: contents
- OT21600: Hire of relevant assets: contents
- OT21700: Corporation Tax Ring Fence: Energy Profits Levy: Contents
- Close sectionOT22000: Interest and Financing: contents
- OT22001: Introduction
- OT22002: Transactions across the Ring Fence
- OT22005: Summary of Statutory Provisions
- OT22006: Qualifying loans
- OT22009: Replacement and Rescheduled Borrowing.
- OT22012: Excluded Loan Relationship debits and credits
- OT22013: Charges paid to associates
- OT22014: Charges which were not allowed against ring fence profits
- OT22020: Sale and leaseback finance charges
- OT22030: The Debt Cap
- Close sectionOT25999: Capital Allowances: contents
- Close sectionOT26000: Research and Development: contents
- OT26001: Introduction
- OT26002: Meaning of oil & gas exploration and appraisal
- OT26005: Judicial Comment on Scientific Research and Oil Exploration
- OT26007: Joint memorandum 1967
- OT26008: 1967 Memorandum - Details
- OT26009: 1967 Memorandum - Successive Stages of Work - Stages 1 & 2
- OT26010: 1967 Memorandum - Successive Stages of Work - Stages 3 & 4
- OT26013: Tribunal reform of 01 April 2009
- OT26015: HMRC view on the 1967 Memorandum
- OT26016: 1967 Memorandum - HMRC view on the Meaning of Field
- OT26017: 1967 Memorandum - HMRC view on exclusions
- OT26018: 1967 Memorandum - HMRC View on end of Stage 3
- OT26026: Using reserve reporting for deciding on the availability of RDAs
- OT26027: 1967 memorandum - gaps between stages 3 and 4 in oil exploration and development
- OT26030: RDA Claims during production operations
- OT26035: Commencement of Trade
- OT26036: Geographical scope of research and development allowances
- OT26041: US Oil & Gas Partnerships
- OT26045: The purchase of the results of past exploration work
- OT26050: Redeterminations & Unitisations
- OT26052: Disposal of a licence interest
- OT26054: Disposal of a licence for an undeveloped area
- OT26056: The allowance of certain drilling expenditure
- OT26058: Treatment of Payments for Production Licences
- OT26060: Farm-ins
- Close sectionOT26105: Ring Fence Expenditure Supplement: contents
- OT26106: Introduction
- OT26108: Conditions for relief: outline
- OT26110: Relevant percentage for calculating the Supplement
- OT26115: Accounting Periods
- OT26120: Limit on number of accounting periods for which supplement may be claimed
- OT26125: Unrelieved Group Ring Fence Profits
- OT26130: Pre-commencement Supplement
- OT26135: Qualifying pre-commencement expenditure
- OT26140: The mixed pool of qualifying pre-commencement expenditure and supplement
- OT26145: Pre-commencement mixed pool : Reduction in respect of disposal proceeds under the Capital allowance Act
- OT26150: Pre commencement mixed pool: Reduction in respect of unrelieved group ring fence profits
- OT26155: Supplement in respect of a post-commencement period
- OT26160: Ring fence losses and qualifying and non-qualifying E&A losses
- OT26165: Ring fence loss - the special rule for straddling periods
- OT26170: Ring fence losses - Post-commencement pools of losses
- OT26175: The reference amount for a post-commencement period
- OT26180: Post-commencement pool: Reduction in respect of utilised ring fence losses
- OT26185: Post-commencement pool: Reductions in respect of unrelieved group ring fence profits
- OT26190: Calculating the supplement due
- Close sectionOT26105: Ring Fence Expenditure Supplement: contents
- OT26106: Introduction
- OT26108: Conditions for relief: outline
- OT26110: Relevant percentage for calculating the Supplement
- OT26115: Accounting Periods
- OT26120: Limit on number of accounting periods for which supplement may be claimed
- OT26125: Unrelieved Group Ring Fence Profits
- OT26130: Pre-commencement Supplement
- OT26135: Qualifying pre-commencement expenditure
- OT26140: The mixed pool of qualifying pre-commencement expenditure and supplement
- OT26145: Pre-commencement mixed pool : Reduction in respect of disposal proceeds under the Capital allowance Act
- OT26150: Pre commencement mixed pool: Reduction in respect of unrelieved group ring fence profits
- OT26155: Supplement in respect of a post-commencement period
- OT26160: Ring fence losses and qualifying and non-qualifying E&A losses
- OT26165: Ring fence loss - the special rule for straddling periods
- OT26170: Ring fence losses - Post-commencement pools of losses
- OT26175: The reference amount for a post-commencement period
- OT26180: Post-commencement pool: Reduction in respect of utilised ring fence losses
- OT26185: Post-commencement pool: Reductions in respect of unrelieved group ring fence profits
- OT26190: Calculating the supplement due
- Close sectionOT26300: Mineral Extraction Allowance: contents
- OT26301: Introduction
- OT26305: Interaction with Other types of Capital Allowances
- OT26310: First-Year Allowances for Ring Fence Mineral Exploration & Access
- OT26315: Rates of writing down Allowances
- OT26320: Acquisition of a mineral asset owned by a previous trader
- OT26325: Acquisition of an oil licence from a non-trader
- OT26330: Acquisition of other assets from non-traders
- OT26335: Limitations on qualifying expenditure on second-hand assets
- OT26340: Definition of Mineral Asset
- OT26345: Definition of mineral exploration and access
- OT26350: Qualifying and non-qualifying expenditure
- OT26355: Qualifying expenditure in oil trades
- OT26360: Restrictions on qualifying expenditure
- OT26370: Disposal events and disposal values
- OT26380: Balancing allowances and charges
- OT26390: Pre-trading expenditure
- OT26395: Migration to UK residence
- Close sectionOT26500: Plant and Machinery: contents
- Close sectionOT26600: Long Life Assets: contents
- Close sectionOT26680: Production Sharing Contracts (PSC): contents
- OT26682: Introduction
- OT26685: What is a PSC?
- OT26690: Cost Recovery and Profit Oil
- OT26695: Expenditure on Plant & Machinery
- OT26700: Capital Allowances and ownership
- OT26710: Deemed Ownership of Assets
- OT26740: The scope of the PSC rules on plant and machinery
- OT26750: Ownership Terms
- OT26755: Provision of Plant & Machinery
- OT26760: Trade Use and Qualifying Purposes
- OT26770: Anti-Avoidance Provision and “Carry” Arrangements
- OT26775: Triggering of the Relief for deemed ownership
- OT26780: The pool value on migration into the UK
- OT26785: Cessation of Relief and Disposal Value
- OT26795: Temporary Cessation of Use
- OT26800: Disposals and Part Disposals of the Contractor's Interest
- OT26805: Cross-Border Disposals
- Close sectionOT26000: Research and Development: contents
- Close sectionOT28000: Decommissioning and Abandonment: contents
- OT28030: Meaning of ring fence trade
- OT28001: Introduction
- OT28010: Outline of the legislation
- Close sectionOT28020: General decommissioning expenditure: contents
- OT28040: Meaning of general decommissioning expenditure
- OT28045: Meaning of general decommissioning expenditure - Expenditure incurred on or after 22 April 2009
- OT28050: Further definitions
- OT28060: Decommissioned plant and machinery used partly for a non-ring fence trade, expenditure incurred on or after 12 March 2008 and before 22 April 2009
- OT28065: Decommissioned Plant and Machinery, expenditure incurred on or after 22 April 2009
- OT28080: Relief for expenditure incurred before cessation of ring fence trade and on or after 12 March 2008
- OT28085: Relief for expenditure incurred before cessation of ring fence trade and on or after 22 April 2009
- OT28100: Relief for expenditure incurred before cessation of ring fence trade and on or before 11 March 2008
- OT28110: Closing down an oil field on or before 11 March 2008
- OT28120: Meaning of abandonment programme
- OT28200: Relief for expenditure incurred after cessation of ring fence trade and on or after 12 March 2008
- OT28205: Relief for expenditure incurred after cessation of ring fence trade and on or after 22 April 2009
- OT28210: Meaning of post cessation period on or after 12 March 2008
- OT28220: Relief for expenditure incurred after cessation of ring fence trade and on or before 11 March 2008
- OT28230: Restrictions on allowances
- Close sectionOT28300: Expenditure connected with reuse of offshore infrastructure: contents
- OT28400: Expenditure on and under Abandonment Guarantees
- OT28410: Meaning of Abandonment Guarantee
- OT28420: Relief for Reimbursement Expenditure under Abandonment guarantees
- OT28430: Relief for expenditure incurred by a participator in meeting a defaulter's abandonment expenditure
- OT28440: Reimbursement by defaulter in respect of abandonment expenditure
- OT28450: Relief for residual liabilities following decommissioning
- OT28460: Buying out abandonment obligations
- OT28470: Relief for contributions to Trust Funds
- Close sectionOT28600: Decommissioning security agreements: contents
- Close sectionOT28700: Decommissioning certainty: contents
- Close sectionOT30000: Capital Gains: contents
- OT30001: Introduction
- Close sectionOT30008: Licences for exploration and exploitation: contents
- Close sectionOT30018: Farm Outs: contents
- Close sectionOT30038: Undeveloped Areas: contents
- OT30040: Introduction
- OT30041: Overseas Licences.
- OT30042: Disposals at arms-length
- OT30043: Definitions 1
- OT30044: Definitions 2
- OT30045: Three Dimensional Co-ordinates
- OT30046: Date of conditional disposals
- OT30047: Areas with more than one prospect
- OT30048: Work Programme Obligation
- OT30049: Exploration Work
- OT30050: Appraisal Work
- OT30051: Definition of Oil
- OT30052: Licensed Area
- Close sectionOT30070: Computational Points: contents
- Close sectionOT30098: Drilling Expenditure: contents
- OT30120: Disposal of Field Interests.
- Close sectionOT30125: Consideration other than cash: contents
- OT30130: Introduction
- OT30131: Subordinated interests
- OT30132: Development Carry
- OT30133: Licence Swaps
- OT30134: Work Obligation
- OT30135: Agreement of the Farmer In to valuation
- OT30136: Licence swaps: Licence Only Consideration - disposals made on or after 22 April 2009
- OT30137: Licence swaps: Mixed consideration received - disposals made on or after 22 April 2009 (1)
- OT30138: Licence swaps: Mixed consideration received - disposals made on or after 22 April 2009 (2)
- OT30139: Licence swaps: Reimbursed expenditure
- OT30140: Time at which non-licence consideration and value of a licence are determined
- OT30145: Definitions
- Close sectionOT30150: Allowable Costs: contents
- Close sectionOT30200: Rebasing of Assets Held at 31 March 1982: contents
- Close sectionOT30295: Valuation of oil assets including shares: contents
- OT30300: Introduction
- OT30301: Post transaction valuations
- OT30302: Other clearances
- OT30305: General principles of valuation
- OT30320: The discounted cash flow methodology of valuing fields - The process
- OT30322: The discounted cash flow methodology of valuing fields - Inputs
- OT30324: The discounted cash flow methodology of valuing fields - Input assumptions
- OT30326: The discount rate and risking
- OT30328: The discount rate and risking - additional factors
- OT30330: The discount rate and risking - other methods of risking
- OT30350: Methodology of valuing prospects
- OT30360: Methodology of valuing exploration acreage
- OT30370: Unquoted shares
- OT30380: Rebasing to 31 March 1982
- OT30382: Cash flow assumptions for rebasing to 31 March 1982
- OT30384: Rebasing to 31 March 1982 for unexplored areas
- OT30386: Rebasing to 31 March 1982 for prospects
- OT30390: Third party information and information sources
- Close sectionOT30440: Extension of Ring Fence: contents
- OT30450: Introduction
- OT30451: Material Disposals
- OT30452: Non Material Disposals
- OT30453: The Ring Fence Rules
- OT30470: Roll Over Relief
- OT30471: Assets used in connection with oil fields - Disposals made before 22 April 2009
- OT30472: Assets used in connection with oil fields - Disposals made on or after 22 April 2009
- OT30473: Assets used in connection with oil fields - Provisional claims for disposals on or after 22 April 2009
- OT30474: Assets used in connection with oil fields - Prevention of Double Claims
- OT30475: Assets used in connection with oil fields - Meaning of Ring fence investment and Disposal Consideration
- OT30476: Assets used in connection with oil fields - Disposals on or after 22 April 2009 - Qualification for Roll Over Relief
- OT30477: Assets used in connection with oil fields - Disposals on or after 22 April 2009 - Qualification for Relief under TCGA92\S153
- OT30479: Reinvestment after pre trading disposal
- Close sectionOT30495: Unitisations: contents
- Close sectionOT30800: Non Residents: contents
- OT30801: Introduction
- OT30805: Disposal of oil and oil related assets
- OT30813: Illustrative Agreements
- OT30818: Illustrative agreements and TCGA92\S276
- OT30820: Meaning of Exploration or Exploitation Activities
- OT30823: Meaning of Exploration or Exploitation Assets
- OT30825: Non-dedicated Mobile Assets
- OT30830: Exit Charges for Branches
- OT30833: Branch exit charges for dedicated mobile assets
- OT30835: Special Exit Charges for Non-Mobile Assets held by a UK Branch
- OT30838: Exit Charges for Assets situated in UK Continental Shelf and used in Foreign Fields
- OT30840: Unquoted Shares
- OT30845: Intra-group transfers
- OT30850: Double Taxation Agreements
- OT30860: Administration and Payment of Tax
- Close sectionOT40000: Non-Residents Working on the UK Continental Shelf: contents
- Close sectionOT40001: Introduction
- Close sectionOT40500: Scope of Exploration or Exploitation Activities
- OT40550: Meaning of “UK”
- OT40600: Meaning of “Exploration or Exploitation Activities
- OT40650: Meaning of “the UK sector of the continental shelf”
- OT40700: Interpretation of “carried on in connection with”
- OT40725: Companies
- OT40800: Independent Contractor Status
- OT40900: Inter-affiliate leasing
- OT40950: Examples of the Scope of taxation on the UK continental shelf
- Close sectionOT41000: Income from Rights: contents
- Close sectionOT41500: Double Taxation Agreement: contents
- OT41501: Outline
- OT41510: Examples of Restrictions on UK Taxation
- OT41520: Other treaty implications
- OT41530: Different types of treaties
- OT41540: Treaties with a restricted definition of the UK confined to land areas & territorial sea
- OT41550: Treaties without an Offshore Activities Article but with an extended definition of the UK including the continental shelf of the UK, land areas and territorial sea areas
- OT41560: Treaties with an Offshore Activities Article - Example 1
- OT41570: Treaties with an Offshore Activities Article - Example 2
- OT41580: Treaties with an Offshore Activities Article - Example 3
- OT41585: Treaties with an Offshore Article Equivalent - Example India
- OT41590: Measurement of Duration
- OT41610: Shipping and Air Transport Articles
- OT41620: The Construction and Interpretation of Treaties
- OT41630: Permanent Establishment and Business Profits Articles
- OT41640: Long term offshore construction type work - Overview
- OT41642: Long term offshore construction type work - Is there a fixed place of business?
- OT41643: Long term offshore construction type work - Is it listed in Article 5 as an example of a Permanent Establishment?
- OT41644: Long term offshore construction type work - Is there a construction project lasting more than a given number of months?
- OT41645: Long term offshore construction type work - An example
- OT41650: Operations of semi-submersible drilling rigs
- Close sectionOT42000: Computation of Profits: contents
- OT42001: Introduction
- OT42010: General Approach
- OT42020: Exclusions from Computation of Profits
- OT42030: Companies
- OT42050: Companies - Double Taxation Agreements - Example
- OT42080: Individuals
- OT42120: Partnerships
- OT42180: Norwegian Partnerships
- OT42220: Treatment of Idle Time Costs
- OT42280: Treatment of Idle Time Costs - Multiple Vessels
- OT42380: Mobilisation & Demobilisation Activities
- OT42400: Mobilisation and Demobilisation Fees
- OT42430: Loan Relationships - General
- OT42440: Loan Relationships - Application to Offshore Contractors
- Close sectionOT42500: Capital Allowances: contents
- OT42501: Outline
- OT42520: Plant & machinery brought into the UK - Entitlement to allowance
- OT42530: Plant & machinery brought into the UK - Open market value but limited to original cost if lower
- OT42540: Plant & machinery brought into the UK - Valuations
- OT42550: Plant & machinery allowances - Disposal events
- OT42560: Plant & machinery allowances - Foreign currency
- OT42570: Part use of plant & machinery - Main rule and single asset rule
- OT42590: Part use of plant & machinery - Reduction of allowances and charges on expenditure in a single asset pool
- OT42600: Part use of plant & machinery - Effect of significant reduction in use for purposes of qualifying activity
- OT42610: Part use of plant & machinery - Treatment of idle time
- OT42620: Rigs as ships
- Close sectionOT43000: Transfer Pricing: contents
- OT43001: Introduction
- OT43060: Interaction with Double Taxation Treaties
- OT43100: Drilling Operating Structures
- OT43110: What is a Rig?
- OT43130: Characteristics of a bareboat charter
- OT43160: Bareboat Charter - Rig market
- OT43170: Bareboat Charter - Types of Day Rates
- OT43200: Bareboat Charter - Day Rates
- OT43280: Day Rates - Semi Submersible v Jack-up
- OT43300: Bareboat Charter - Transfer Pricing Challenge
- OT43320: Determining the transfer price - Approved Methods
- OT43330: Bareboat Charter - - Comparable Uncontrolled Price
- OT43360: Bareboat Charter - Resale Price Method
- OT43380: Bareboat Charter - Cost Plus Method
- OT43400: Bareboat Charter - Transactional Net Margin Method
- OT43450: Bareboat Charter - Profit Split Method
- OT43455: Advance Pricing Agreements
- Close sectionOT43500: Organisation of work: contents
- OT43501: Large Business - Main responsibilities
- OT43550: Relationship with Local Compliance
- OT43600: Detection of non-resident offshore contractors liable to tax in the UK
- OT43650: Self -employed Consultants
- OT43700: Tax recovery powers
- OT43750: Exempting licensees from responsibility for unpaid contractors tax
- OT43780: Identification and assessment of Capital Gains liabilities
- OT43800: Responsibilities of Specialist Investigations Glasgow
- OT43850: Responsibilities of Centre 1 for PAYE
- OT43900: Responsibilities of Recovery Offices to collect tax
- OT43950: Responsibility for divers & diving supervisor
- Close sectionOT44000: Self Assessment and Appeals: contents
- Close sectionOT44500: Notification of Payments to Third Parties: contents
- Close sectionOT45000: Recovery of Tax: contents
- OT45001: Outline
- OT45050: Recovery powers from licence holder
- OT45100: Liability of licence holder
- OT45140: Scope of recovery powers
- OT45150: Apportionment of tax
- OT45200: Review of suitability for recovery of tax
- OT45400: Apportionment procedure - Pipelines
- OT45420: Notices - Advance notice of formal action
- OT45450: Notices - Formal notice
- Close sectionOT45500: Exemption for Licensee from Recovery of Tax: contents
- OT45501: General background
- OT45550: Exemption certificate applications
- OT45600: The exemption certificate applications process
- OT45620: The exemption certificate applications form
- OT45680: Exemption certificate applications: New Cases
- OT45700: Specimen exemption certificate
- OT45750: Refusal of application for exemption certificate
- OT45800: Cancellation of exemption certificate
- Close sectionOT46000: Divers & Diving Supervisors Employees: contents
- Close sectionOT46500: Construction Industry Scheme: contents
- Close sectionOT50000: The Oil Contractors Ring Fence: contents
- OT50001: Introduction
- OT50005: Scope
- OT50010: Relevant assets
- OT50020: Associated person
- Close sectionOT50030: Calculating the hire cap: contents
- OT50050: The effect of the ring fence
- OT50060: Anti avoidance provision
- OT50070: Leasing arrangements
- OT50080: The excess above the hire cap
- OT50090: Transitional provisions at commencement
- Close sectionOT60000: Transferable Tax History: Contents
- OT60010: Introduction
- Close sectionOT60015: Elections and TTH Cap: contents
- OT60020: Transactions that can use the TTH mechanism
- OT60025: Restrictions on who can enter into transactions which can use the TTH mechanism
- OT60030: The start date
- OT60040: Details of what can be included as TTH
- OT60050: TTH elections and directions relating to information and declarations the election must contain
- OT60055: Making a TTH election and the time limit
- OT60070: Corresponding with HMRC by email
- OT60075: TTH Cap
- OT60080: Uplifted Decommissioning Costs Estimate
- OT60085: Adjustments to the Net Cost Amount
- OT60090: Standardised Inflation Adjustment
- OT60095: DSA estimate must be reasonable
- Close sectionOT61000: Administration and Enquiries: contents
- OT61010: Election - enquiries
- OT61020: Election - approval
- OT61030: Election - effective date
- OT61040: Election - withdrawal
- OT61050: Election - Amounts discovered to be incorrect
- OT61060: Election - Multiple interests in a field
- OT61070: Claims to set losses against TTH - enquiries
- OT61080: Record keeping
- Close sectionOT62000: Effect of a TTH election on the seller: contents
- Close sectionOT63000: Effect of a TTH election on the buyer: contents
- Close sectionOT64000: Activation: contents
- Close sectionOT65001: Tracking profits of the asset: contents
- OT65110: Tracking profits general overview
- OT65120: Calculation of tracked profits
- OT65125: Interest and financing costs
- OT65130: Basic example of tracking
- OT65135: Tracking of multiple TTH assets
- OT65140: Tracking of multiple holdings of the same asset containing TTH
- OT65145: Tracking following cessation of production
- OT65150: Losses in year
- OT65155: Reporting tracked profits to HMRC
- OT65160: Commencement of Tracking
- OT65170: Senior Tracking Officer Certificate
- Close sectionOT66000: TTH allocation on a loss carry back: contents
- OT66010: Introduction
- OT66020: Total activated TTH amount - first loss-making period
- OT66030: otal activated TTH amount - subsequent loss-making period
- OT66040: Closing balance of activated TTH
- OT66050: Additional activated TTH amount
- OT66060: TTH reduction amount
- OT66070: Closing balance of the total TTH amount
- OT66080: Allocation of the Total activated TTH amount
- OT66090: Allocation of activated TTH - Example
- Close sectionOT67000: Supplementary Charge: contents
- Close sectionOT68000: Onward Sales: contents
- OT68010: Introduction
- OT68020: Original TTH amount treated as eligible ring fence profits
- OT68030: Effect on the original purchaser
- OT68040: Default treatment
- OT68050: Opt-out treatment
- OT68060: Supplementary charge
- OT68070: Effect of an onward sale on the new purchaser
- OT68080: Subsequent onward sales
- OT68090: Retained decommissioning
- Close sectionOT69000: Miscellaneous: contents