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HMRC internal manual

Oil Taxation Manual

Capital gains: extension of ring fence: roll over relief


Except for cases already determined by the Special Commissioners or a Court before 14 May 1987 rollover relief was not available in respect of gains on UK or UK Continental Shelf licence interests where the disposal occurred at any time before 1 July 1999.

From 1 July 1999 rollover relief should be allowed on UK or UK Continental Shelf licences on the basis that they are land occupied and used for the purposes of the trade.

Rollover of gains on UK licences is subject to the restrictions applying to ‘material disposals’ (see OT30451).