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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: Appropriations of oil


Where oil is not sold but is appropriated to a non-ring fence activity (i.e. to refining or to any use except use for field production purposes) the company is treated as having at the time of the appropriation sold the oil in the course of its ring fence trade and bought it for purposes of its non-ring fence trade at a price equal to the market value used for PRT (or which would have been so used but for the fact that the appropriation was from an exempt gas field).