Introduction

FA 2008 introduced legislation that allowed participators in a PRT field to elect to make that field non-taxable. The legislation included the condition that HMRC had to approve an election and HMRC would only do so if evidence showed that there would be no assessable profits accruing to any participator in that field in future, or if there were, they would be fully covered by oil allowance. These rules required the provision of a substantial quantity of data to provide assurance to HMRC that there was no tax risk to the Exchequer before a field could be opted out of the PRT regime.

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