Marathon have lost their appeal in the First Tier Tribunal for their claim for relief for expenditure incurred under an “acceleration” scheme which they entered into in 2008 under the special decommissioning relief provisions in s163/s164 CAA 2010 as they applied at that time. Marathon Oil U.K., LLC (“MOUK”), was the licence holder for a number of the group’s North Sea assets. They entered into an arrangement to secure relief in advance of decommissioning work actually being carried out in […]

Philip Hammond presented his Budget today. This note sets out the main announcements that are targeted at oil and gas companies operating in the UK and UKCS. TTH for late life assets The main item directly affecting the oil and gas industry was the announcement regarding the proposed introduction of transferable tax history (TTH). The intent of the proposals is to facilitate the transfer of mature field interests to companies which would otherwise be unable to obtain effective relief for […]

CW Energy is pleased to announce that it has become part of legal and professional services group Gordon Dadds Group plc, a fast growing legal and professional services business headquartered in London with a significant back office and technology platform based in Cardiff. Joining the Group will give our clients access to a wider range of legal and professional services as well as enhancing the long term sustainability of the firm. Commenting on the acquisition Adrian Biles, Chief Executive Officer of […]

Issue Although IAS 12 requires one to take into account uncertainties when accounting for tax there is no specific guidance of the approach to be taken. IFRIC 23 is being introduced to clarify the accounting approach that is required to be taken. IFRIC 23 interpretation in assessing uncertainty The IFRIC deals with 4 areas relevant for recognition and measurement 1. Whether tax treatments should be considered singly or collectively In deciding whether a tax treatment should be considered independently or […]

We want to draw your attention to the implementation of the rules in the Criminal Finances Act 2017 creating an offence of corporate failure to prevent the facilitation of tax evasion. The rules were set out in the Act, but were only to take effect once secondary legislation was passed. This has now been done. The Criminal Finances Act 2017 (Commencement No 1) Regulations, SI 2017/739, implements the rules from 30 September 2017. The rules introduce a new offence. The […]

Corporation Tax loss reforms Impact on ring fence losses   Readers will be aware that the Government is proposing some quite significant changes to the rules dealing with the use of carried forward losses. Draft clauses were included in the Finance Bill published earlier this year. These provisions were however pulled from the truncated Bill which has passed into law, but revised legislation to be included in the Finance Bill to be published after the summer recess, has recently been […]

The Finance Bill as originally introduced has been dramatically reduced in scope in order to pass into law prior to the general election. For companies the key points are the omission of; the new loss relief rules (for brought forward losses), the interest deduction restrictions, and the amendments to the Substantial Shareholding Exemption rules. In addition, the legislation dealing with the relaxation of the PRT opt-out rules is to be omitted. The Government minister stated in the relevant Finance Bill […]

Possible unwelcome changes for Upstream groups  The proposals for the changes to the loss rules were published on 20 March. The draft legislation runs to over 100 pages.  These new rules are intended to increase flexibility in the use of losses whilst introducing restrictions to prevent the relief from brought forward losses/deficits from exceeding 50% of the profits of a period. These rules will also apply to the use of ring fence losses against non-ring fence profits (subject to some […]