A participator could, were it not for OTA 1983, Sch. 2, para. 12, avoid the charge on tariff receipts for transporting, initially treating or initially storing oil by buying the oil from his customer at the place of extraction (or at any other place offshore) at the landed price less the tariff, and selling it onshore at the landed price; the profit on this trading transaction would then fall outside PRT. This is prevented by deeming the trading profit to be a tariff receipt.

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