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HMRC internal manual

Oil Taxation Manual

Non-residents working on the UK continental shelf: recovery of tax: recovery powers from licence holder

Under TMA70\S77C an Officer of HMRC may serve a notice on the holder of a licence granted under Part I of the Petroleum Act 1998 requiring the holder to pay within 30 days of the issue of the notice unpaid tax assessed by virtue of CTA2009\S1313, ITTOIA2005\S874 or TCGA92\S276 and interest under TMA70\S86 in respect of:

  1. Profits from activities related to the licence.
  2. Profits from “exploration or exploitation rights” [as defined in the above sections connected with activities under the licence.
  3. Chargeable gains arising on the disposal of rights within (b).

The notice issued must give particulars of the manner in which the amount to be paid by a licence holder was determined - TMA70\S77C(1). The notice will be issued by the Large Business, Oil & Gas sector.

Tax assessed under the Income Tax (Earnings and Pensions) Act 2003 is not recoverable from a licence holder (TMA70\S77B(4)).