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HMRC internal manual

Oil Taxation Manual

From
HM Revenue & Customs
Updated
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Capital gains: non residents - meaning of exploration or exploitation assets

Exploration and exploitation assets are defined, broadly, as assets used at some time in connection with exploration or exploitation activities carried on in the UK or on the UK continental shelf, where the assets are either:

  • non-mobile (for example, a pipeline, or a fixed production platform), or
  • mobile (for example a floating production platform or offshore drilling rig) and dedicated to an oil field in which the disposer, or a person connected with the disposer, is, or has been, a participator.

It should be emphasised that where a mobile asset is concerned, it must be dedicated to the field at the time of disposal (see OT30833).

The terms ‘mobile’ and ‘dedicated to a field’ have the meaning given to them for PRT purposes (see TGCA92\S276(5) & OTA75\Part 1).