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HMRC internal manual

Oil Taxation Manual

Non-residents working on the UK continental shelf: recovery of tax: scope of recovery powers

Recovery may be made from a licensee in respect of part of the unpaid tax assessed where:

  1. activities in more than one licensed area gave rise to the profits assessed; or
  2. the tax assessed includes but is not limited to tax assessed under CTA2009\S1313, ITTOIA2005\S874 or TCGA92\S276.

The provision at (a) above ensures that the recovery of unpaid tax is not just restricted to cases where the whole of the unpaid tax relates to profits from work carried out by a contractor in one licensed area only - TMA70\S77B(5).

The provision at (b) above is aimed at cases where a non-resident company carries on some activities through a UK permanent establishment and others through a permanent establishment outside the UK and the profits from both permanent establishments are included in the one UK assessment - TMA70\S77B.