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HMRC internal manual

Oil Taxation Manual

PRT: supplement - interaction with other provisions

Supplement has a number of important applications in PRT. Apart from providing additional 35% relief to a participator for qualifying expenditure incurred up to and including its net profit period (see OT12025), expenditure upon which supplement is allowed, plus that supplement:

  • makes up the safeguard capital base against which participator returns on capital are measured for the purpose of calculating any safeguard reduction (OTA75\S9(3)), see OT17550 
  • can be the subject of a ‘spreading election’ (OTA75\SCH3\PARA9), see OT13100 

and 10% of qualifying expenditure (but not the supplement):

  • can be surrendered to particular fields as a cross field allowance (FA87\S65), see OT13020.