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HMRC internal manual

Oil Taxation Manual

PRT: transfer of licence interests - transfers of oil


This paragraph provides that where the new participator (NP) acquires rights over oil won, but not sold and delivered, NP rather than the old participator (OP) is charged to PRT on the eventual sale. This may lead to an odd result. Where, for example, OP transfers its interest on 1 January it will have an opening stock figure and nothing else. The resulting loss can be transferred to NP under FA80\SCH17\PARA7 (see OT18050), but with a transfer between associated companies no objection need be taken to the opening stock appearing in NP’s computation of assessable profit for the transfer period rather than in OP’s computation.