Commentary

D7.925A Transferable tax history

Corporate tax
Corporate tax | Commentary

D7.925A Transferable tax history

Corporate tax | Commentary

D7.925A Transferable tax history

Finance Act 2019 introduced a transferable tax history (TTH) mechanism for transfers of UK oil and gas field interests where Oil and Gas Authority (OGA) consent for the transfer is received on or after 1 November 20181. These rules allow companies selling UK North Sea oil and gas fields to jointly elect with the buyer to transfer some of their ring fence corporation tax and supplementary charge history to the buyers of those fields2. The buyers will then be able, to the extent they do not have sufficient own tax history, to set the losses derived from the costs of de-commissioning any fields against the TTH. The election must be made on a date between the licence transfer date and 90 days after that date (or, if later, 1 June 2019)3. The election must be approved by an officer of HMRC4.

The TTH mechanism allows an oil company that is selling an oil licence containing a field interest to elect to transfer a portion of its historic ring fence profits and the associated corporation tax and supplementary charge paid on those profits to the company buying the licence, provided the buyer is unconnected with the seller (unless there is a corporate restructuring or a hive

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