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HMRC internal manual

Oil Taxation Manual

HM Revenue & Customs
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Capital Allowances: Production Sharing Contracts - Cross-border Disposals

Where a participator acquires an interest from a contractor who is not resident in the UK, no disposal value will have been brought into account on the seller. This does not, however, prevent the buyer from obtaining any relief at all on any consideration paid for the plant. It simply means that as there is no disposal value, then there is no “excess” to be disregarded.

Oil extraction assets do not normally increase in value, and in an arms length scenario, it is unlikely that the amount of consideration paid will give cause for concern. Inter-affiliate transactions will be subject to the normal rules in CAA01\S213, CAA01\S214 & CAA01\S218 which limit the qualifying expenditure in such a case to the lower of cost or market value.