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HMRC internal manual

Oil Taxation Manual

From
HM Revenue & Customs
Updated
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Corporation Tax Ring Fence: The valuation of oil: Other non-arm’s length transactions

CTA10\S282, CTA10\S285

CTA10\S282 & S285 cover disposals and appropriations in circumstances where PRT rules do not apply, for example

  • where the company is entitled to oil from a field although not a participator, or
  • where oil is won before determination of a field.

The same rules apply as for CTA10\S280 + in general, with the market value to be taken as the PRT value for the day of delivery or appropriation.