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HMRC internal manual

Oil Taxation Manual

Corporation Tax Ring Fence: Interest Received by Ring Fence Companies

The guidance at BIM40800 onwards deals with the treatment of the interest and dividend income of a person carrying on a trade, profession or vocation. It explains the factors to take into account in deciding whether interest income should be taxed as a trade receipt (see BIM40805).

HMRC take the view that lending money at interest is not an integral part of oil exploitation and is not a ring fence activity but one step removed.