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HMRC internal manual

Oil Taxation Manual

Decommissioning and abandonment: decommissioning security agreements: loan relationship debits and credits

Taxable loan relationship credits may arise when a company makes a payment into a decommissioning security settlement to meet future decommissioning costs. If these funds are invested and earn interest then the income may be taxed twice; first on the trustee of the decommissioning security settlement and second as a loan relationship credit of the company.

CTA2010\287A which removes this possibility by providing that loan relationship debits and credits are not brought into account in respect of a company’s loan relationships, where they arise in relation to a decommissioning security settlement.