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HMRC internal manual

Oil Taxation Manual

PRT: long-term assets - basic conditions for relief


OTA83\S3 provides full front-end relief for long-term asset (see OT11025) expenditure in a field.

The conditions for relief are that

  • the expenditure is incurred on the acquisition, creation or enhancement of an asset (or an interest in the asset) for an OTA75\S3(1) purpose (see OT09025),
  • at the end of the ‘relevant claim period’ the asset is used, or is expected to be used, in connection with the field,
  • at that point the asset is, or is expected to be, a long-term asset,
  • and the expenditure does not relate to a non-dedicated mobile asset (in which case different rules apply, see OT11100).

Relevant Claim Period

The relevant claim period for long-term assets is the claim period in which the expenditure is incurred unless either

  • the asset is a ‘brought-in asset’ (see OT11500), in which case the relevant claim period is the claim period of first use (discounting in the case of a mobile asset any claim period in which it was not dedicated to that field), OTA75\S3(5)(b), or
  • the asset has previously been a non-dedicated mobile asset, in which case the relevant claim period is the period in which the asset becomes dedicated, OTA75\S3(5)(c).

Application to OTA75\S3

As well as the link to a OTA75\S3(1) purpose, which is established by OTA75\S12(2), OTA83\S3(6) provides that the following provisions apply to the allowance of long-term asset expenditure under OTA83\S3:

  • OTA75\S3(3), prevention of double allowance, see OT09425 
  • OTA75\S3(4), disallowable expenditure, see OT09450 
  • OTA75\S3(5), allowance of supplement, see OT12050 
  • OTA75\S3(5A), apportionment of supplement, see OT12500.

The expenditure apportionment rules in OTA75\S3(6) (see OT09375) and OTA75\S3(7) (see OT09400) do not however apply as they relate to operating expenditure. Apportionment of long-term asset expenditure is considered at OT11400.