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HMRC internal manual

Oil Taxation Manual

Non-residents working on the UK continental shelf: computation of profits: general approach

There are no special rules in UK domestic law for computing trading or professional profits for CTA2009\S1313 and ITTOIA2005\S874 purposes. The profit is arrived at by taking the income relating to the relevant activities and allowing a deduction for the associated expenditure. The normal computational provisions that govern the calculation of profits for tax purposes are then applied - for example, the prohibitions listed in CTA2009\S53 and S54 for companies. Losses are computed in the same manner as profits.

In addition, the transfer pricing legislation applies to services provided by connected persons such as intra group and head office services, and guidance on Chapter 7 of the OECD Transfer Pricing Guidelines is given at INTM464050.