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HMRC internal manual

Oil Taxation Manual

Transmedian Fields

If only part of an oil bearing structure falls within the United Kingdom Continental Shelf and the other part is under the jurisdiction of another country, exploitation will depend upon an agreement between the UK Government and that of the other country. Such an agreement will provide for the apportionment of the oil between the participators in the UK field and other persons having rights, interests or obligations in the foreign sector of the field. Fields are determined as described at OT01007 

FA80\S107 requires a participator’s share to be determined on the basis that the whole of the oil won is the same as the amount of oil apportioned to the UK Sector under an Agreement as above. Returns are to be made on that basis. Otherwise, with exceptions, the oil field is to be deemed to include the foreign sector which itself is to be deemed a designated area. The exemptions to this deeming are the appointment of the Responsible Person, abortive exploration expenditure, exploration and appraisal expenditure (via OTA75\S5A(2A)) and the application of FA73\S38(4) (taxation of non-resident persons active in UK designated areas).

If as a result of a redetermination of a field (see OT18250) participators are repaid or granted a credit in respect of revenue (OTA75\S3) expenditure previously allowed for PRT the expenditure allowable in the claim period in which the repayment or credit is received is to be reduced by the amount of that repayment or credit (FA80\S107(4)). If necessary, OTA75\Sch4\Para6 (recovery of deductions for allowable expenditure) is to be applied. Repayment of any capital amount is dealt with as a disposal receipt (see OT15000).