HMRC internal manual

Oil Taxation Manual

OT18630 - PRT Compliance: risk assessment - regime integrity work

Responsibility for maintaining the integrity of the PRT regime lies with the PRT Team.

LB Oil & Gas has an overarching administrative responsibility to ensure an even handed approach to the correct assessment of PRT. We consider the need to review and agree gas methodologies (including valuations of ethane, used for petrochemical purposes) falls within that responsibility. We therefore expect all companies, including Low Risk customers to continue to discuss their methodologies with us. However with Low Risk customers, once we have agreed a methodology, we would not expect to revisit the basis unless we are conducting a wider review or we have reason to reassess the position; for example when the Low Risk relationship ends or because of significant changes to the gas market that might make the method obsolete.

The occasion for reviewing the Low Risk status, or a project, might be an appropriate time for reviewing the methodology. Should this happen, we would open an enquiry for the period which was current at the time. Subject to the ‘discovery’ provisions in Paragraph 12 Schedule 2 OTA 1975 we would not seek any retrospective adjustment.