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HMRC internal manual

Oil Taxation Manual

Non-residents working on the UK continental shelf: recovery of tax: apportionment procedure - pipelines

Where work carried out by the defaulting contractor is reported as relating specifically to a pipeline serving a number of fields, it will be necessary to apportion the unpaid tax between the licences involved. Equity interests in a pipeline may or may not follow those of the holders of licences, whilst a licence holder may have no equity interest in the pipelines serving his field, but meet his obligations by tariff payments. HMRC aims to avoid complex computations in these situations. Where such an apportionment is necessary, and the method of achieving that apportionment is not obvious, LB Oil & Gas will consult with the pipeline operator in advance of issuing the notice to agree a method of allocation back to the respective licences.