797-000 Treatment of tariff and disposal receipts following a change in field or asset ownership
Anti-avoidance provisions introduced in 1999 are designed to prevent companies being able to restructure their interests in oil fields and infrastructure, so as to escape PRT liabilities on certain tariff or disposal receipts. These apply where tariff income or disposal receipts from a non-mobile, qualifying asset are assessable for PRT on a participator in a field. They cover the situation where the tariff or disposal receipts in respect of a qualifying asset would otherwise become assessable in a different field, following:
•transfer of the field to another company;
Want to read more?
This content requires a Croner-i Tax and Accounting subscription.