Sales of oil and gas

Unless a sale of oil is already subject to adjustment under CTA 2010, s. 281 or s. 284, additional rules may apply to such sales (TIOPA 2010, s. 217(3)).

The additional rules apply where:

extraction rights in relation to the oil are exercisable by a company (the ‘producer’) other than the buyer; and

at the time of sale, at least 20% of the producer’s ordinary share capital is owned (directly or indirectly) by the buyer and/or companies linked to the buyer.

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