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HMRC internal manual

Oil Taxation Manual

HM Revenue & Customs
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Non-residents working on the UK continental shelf: transfer pricing: bareboat charter - resale price method

This is the second of the methods referred to in OT43320. Paragraphs 2.14 to 2.31 of the OECD Guidelines indicate how the resale price method applies to the sale of goods, and that its use is aimed at marketing type operations. It is not considered that the method translates suitably to drilling operations because significant value is usually added to the lease rents by the provision of drilling services as well as by the rig performance itself.