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HMRC internal manual

Oil Taxation Manual

Non-residents working on the UK continental shelf: organisation of work: identification and assessment of capital gains liabilities

As explained at OT30801+ liability for capital gains tax or corporation tax on capital gains may arise by virtue of TCGA92\S276 where there is:

  • A disposal by a non-resident of certain rights and other assets connected with a UK oil field, or
  • A disposal by a non-resident of shares in an unquoted company deriving the greater part of their value directly or indirectly from assets within the first bulleted item or
  • A deemed disposal of certain mobile assets formerly dedicated to a UK oil field.

Tax Specialists dealing with the ring-fence corporation tax computation for the relevant field participator are alert to the need to identify cases of potential liability of a non-resident, in respect of events listed above. Where appropriate they obtain computations and assess the non-resident on the gain and if assessed tax remains unpaid after it becomes due they take the necessary steps to recover the tax from the relevant licence holder (see OT45000+).