23 Sep 2022

Mini Budget 23 September 2022: No change for oil and gas sector

Today’s announcements by the Chancellor Kwasi Kwarteng did not contain any changes to the current corporate taxation rules specifically aimed at the oil and gas sector. In particular, there was no announcement of a change to the energy (oil and gas) profits levy enacted in July this year. CW Energy continues to monitor the implications of this levy, working with clients to understand its impact. For industry generally, as widely predicted the non-ring fence corporation tax rate will not be […]


15 Sep 2022

CWE under new ownership

After nearly five years of being part of the Ince group, Phil Greatrex and Paul Rogerson have reacquired the CWE business from Ince. There will be no changes to the running of the client-facing part of the business. All of the partners and staff of CWE will carry on in their original capacities and can be contacted using their existing details as set out on our website. We are now looking forward to developing the business as an independent […]


31 Aug 2022

New Windfall Tax on the UK Oil & Gas sector

A new 25% tax on the UK upstream oil and gas industry is being introduced with effect from 26 May 2022, to be known as the Energy Profits Levy. The levy is intended to apply until 31 December 2025. It will be charged on the same profits that are already subject to ring fence corporation tax (RFCT) and supplementary charge, giving a combined rate of 65%. The RFCT profits are, however, adjusted by the disallowance of any loss relief, financing […]


14 Jul 2022

Energy Profits Levy – now enacted

The Energy Profits Levy (EPL) rules have now been finalised, and the rules are contained in the Energy (Oil & Gas) Profits Levy Act 2022. The Act passed through the House of Commons stages on 11 July 2022 and received Royal Assent on 14 July 2022. Our newsletter of 22 June 2022 ( referred to the consultation on the draft legislation, but the Bill as finalised reflects only two material changes of note. Petroleum Revenue Tax This change is to […]


22 Jun 2022

Energy Profits Levy – draft legislation published for consultation

The Energy Profits Levy (EPL) draft legislation has now been published for consultation. The consultation period closes on 28 June 2022. We understand that it is intended to have EPL enacted before the Summer recess but that the EPL legislation will not be substantively enacted for accounting purposes before 30 June 2022. The comments below reflect the current draft, but we do not expect there to be much change given the compressed legislative timetable. As expected the EPL applies to […]


26 May 2022

Chancellor announces a new oil and gas tax charged at 25%

This afternoon the Chancellor announced the recently anticipated, following significant political pressure, tax rise on the profits of companies that produce oil and gas from the UK and UK Continental Shelf. It does not apply to other energy sector players, such as the producers of green energy, as had been predicted in the Press. Rather than increase the rates on existing taxes the Chancellor chose to introduce a new oil and gas tax called the Energy Profits Levy.  The Energy […]


23 Mar 2022

Spring Statement 2022

The Chancellor delivered the Spring Statement 2022 today. Despite the speculation and calls for a windfall tax there was no announcement on any changes to the oil tax rates.  Therefore, the rates will continue to be those currently enacted being 30% for ring fence corporation tax and 10% for the supplementary charge to corporation tax. In addition, there was no announcement on any changes to the calculation of profits chargeable to ring fence taxation.  Neither was oil and gas taxation […]


14 Mar 2022

Scope of the ring-fence: Result of the appeal in the Royal Bank of Canada case

In August 2020 we published a newsletter on a First-tier Tribunal (‘FTT’) case that considered whether an oil and gas royalty interest held by a non-UK resident gave rise to ring-fence income and whether the relevant treaty allowed HMRC to tax the income.  That newsletter can be found here: As we reported at the time the taxpayer lost on both counts at the FFT and appealed. The appeal was heard by the Upper Tribunal (‘UT’) in December and the […]


09 Feb 2022

Proposed changes to taxation of profits for multinational groups – Pillar Two

In our newsletter in July 2021, we summarised and commented on the potential changes to the taxation of profits for multinational groups published by the OECD/G20.  That newsletter can be found here The OECD issued a report at the end of December 2021 that sets out details on how Pillar Two rules are to be implemented (“Model Rules”).  Pillar Two deals with the Global Anti-Base Erosion (“GloBE”) rules which provides for the introduction of a minimum corporate tax rate […]


25 Jan 2022

Notification of uncertain tax treatments – revised guidance

In our newsletter last year we summarised and commented on the proposed rules for the notification of uncertain tax treatments.  That newsletter can be found here Since then the relevant statutory provisions have been included in Finance (No.2) Bill 2021-2022, and last week revised draft HMRC guidance was published, subject to a short period of consultation.  The consultation will run to 1 February 2022. The big change in the Finance Bill was the omission of the notification requirement where […]