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HMRC internal manual

Oil Taxation Manual

PRT: valuation of non-arm's length disposals and appropriations - gas - valuation of light gases from 1 January 1994 - none specific field contracts

There is no reason in principle why an inter-affiliate contract covering an unspecified source of gas should not be accepted for tax purposes if its terms and prices satisfied the arm’s length principles. There may however be difficulties identifying the source of the gas used to satisfy the contract and this needs to be examined. The proposed allocation to the originating fields of the gas sold needs to be carefully checked.