HMRC internal manual

Oil Taxation Manual

PRT: transfer of licence interests - participation rights

OTA75\SCH3\PARA6A is concerned with BNOC participation rights, and the creation of such rights by the transfer of a right to oil could be seen as coming within the definition of a field transfer.

However, LB Oil & Gas has confirmed that it will not regard FA80\SCH17 as applying in these circumstances.