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HMRC internal manual

Oil Taxation Manual

PRT: allowable losses - transfer of licence inerests

The following provisions of FA80\Sch17 deal with the treatment of losses where there is a transfer of a licence interest, namely

  • FA80\Sch17\Para7, transfer of unused losses by old participator to new, see OT18050.
  • FA80\Sch17\Para14, surrender of new participator losses to old participator, see OT18120.
  • FA80\Sch17\Para15, carry back of terminal losses, see OT18130.

A loophole in the OTA75\S6 rules relating to the calculation of an allowable unrelievable field loss (UFL) where there has been a transfer of field interest was closed by the amendments made by FA01\S101 and the enactment of FA01\Sch32, see OT16500.