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HMRC internal manual

Oil Taxation Manual

PRT: associated party transactions - provision of fuel oil

OTA75\Sch4\Para 2(4)(b)

If a downstream refining company provides an affiliate North Sea company with fuel oil for platform use, establishing the cost price will involve the measurement of production costs. Regard must therefore be had to the precise arrangements in place and it will again be important to isolate and exclude any disallowable ingredients (depreciation, finance costs etc.).