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HMRC internal manual

Oil Taxation Manual

PRT: transfer of licence interests - treatment of overriding royalty


Where part of the consideration for the transfer of a licence interest is the granting to the old participator of an overriding royalty interest, the normal rules in OTA75\SCH3\PARA6 apply and for PRT purposes the royalty oil is charged to PRT on the new participator, see OT18320.