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HMRC internal manual

Oil Taxation Manual

From
HM Revenue & Customs
Updated
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Capital gains: extension of ring fence: material disposals

TCGA92\S197

TCGA92\S197 applies to gains or losses arising on material disposals. These are gains or losses arising on or after 13 March 1984 in pursuance of a transfer by a participator in an oil field, of the whole or part of his interest in the field, from:

  1. a disposal of an interest in oil to be won from the field or
  2. a disposal of an asset used in connection with the field.

Where a disposal is deemed to take place under TCGA92\S179(3) (Companies leaving groups) and the asset was acquired from a group company for whom the disposal was within TCGA92\S197(1); the disposal of an interest in oil to be won from the oil field or of an asset used in connection with the field; then the deemed disposal is also a material disposal.