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HMRC internal manual

Oil Taxation Manual

HM Revenue & Customs
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Corporation Tax Ring Fence: The valuation of oil: Non-arm’s length disposals


CTA10\S281 covers the disposal of oil which, for PRT purposes, has been charged by reference to its market value under OTA75\S2 (or would have been but for the fact that the disposal was of gas exempt from PRT under OTA75\S10), rather than on its sale price. The oil is treated for CT purposes as having been sold by the seller and purchased by the purchaser at the market value used for PRT purposes.