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HMRC internal manual

Oil Taxation Manual

Corporation Tax Ring Fence: PRT paid by Foreign Field Participators

Participators in foreign fields are chargeable to PRT on consideration received or receivable for the UK use of foreign field assets, or for the disposal of those assets in accordance with OTA83\S12 and OTA83\Sch4. In computing such a participator’s liability to CT, any PRT paid will be allowed as a deduction on the same basis as would apply if it was a participator in a UK Field.