28 Apr 2017

Finance Bill 2017

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 […]


05 Apr 2017

Corporation Tax loss rules; Finance Bill 2017 proposed amendments.

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 […]


08 Mar 2017

2017 Spring Budget

The Chancellor delivered the last ever Spring Budget today. There were very few specific oil and gas measures in the announcements. Those having an impact on the regime are set out below. Late life assets The main new Budget announcement is that there is to be a further review of late life assets. A Treasury discussion document is to be issued on 20 March and it is anticipated that further consultation with interested parties will take place over the following […]


03 Jan 2017

Staff Changes

We are pleased to announce that Ian Hack, who joined CW Energy in 2012 after a long career with HMRC, has been made a Director of CW Energy LLP. This promotion recognises Ian’s increasingly strong contribution to the business since joining the firm.       We are also pleased to announce that Janusz Cetnarowicz, who was a director and founder member of CW Energy Tax Consultants Ltd in 1990 has been appointed a partner of CW Energy LLP with effect […]


22 Dec 2016

Season’s Greetings from CW Energy

As in previous years and as an alternative to sending out a Christmas card we are making a charitable donation to both the Multiple Sclerosis Society and the charity Dogs for Good.


23 Nov 2016

2016 Autumn Statement

The Chancellor delivered his Autumn Statement today. There were no new fiscal measures directed at the oil industry apart from an announcement that petroleum revenue tax (PRT) administration is to be simplified with immediate effect. The PRT administrative changes are: firstly, that the PRT opt out election process is to be simplified; and secondly for participators who choose not to opt out the returns process will be simplified. Non-taxable field election It has been possible to opt out of the […]


13 Sep 2016

EITI and The Reports on Payments to Governments Regulations 2014; a sense of déjà vu.

Summary Qualifying Companies are under an obligation to disclose information under The Reports on Payments to Governments Regulations (“the Regs”).  Certain selected companies have also received the EITI questionnaire templates. Whilst the EITI regime is “voluntary” the EU sponsored regime under the Regs is compulsory and requires certain companies to make a return in a prescribed form with Companies House. The first payments covered are those made in 2015 and for a company with a December year end the deadline […]


07 Sep 2016

Finance Bill finishes third reading in the House of Commons

The Finance Bill 2016 completed its third reading in the House of Commons yesterday (6th), and has now been passed on to the House of Lords. As it is a money bill, its terms cannot be amended by the House of Lords so the committee stage, report stage and third reading there are just formalities.  The first reading in the Lords also took place yesterday and the second reading and remaining stages are scheduled for 13th September, after which the […]


24 Aug 2016

Changes to Derivative Contract Rules

Changes to derivative contract rules – reminder of time limit for non-large companies. Deadline fast approaching for small and medium sized companies to make election Some companies may not be grandfathered even though fair valuing has been the policy Election should be made if there is any doubt otherwise companies will be taxed on fair value movements Detail Readers will recall from our newsletter of April 2015 that there are strict time limits to make the election to operate the […]


22 Jul 2016

Loss streaming: Back where we started?

The Upper Tier Tribunal have overturned last year’s First Tier Tribunal decision in the Leekes V HMRC  case, and held that losses are required to be streamed even where the whole of the predecessor’s trade is transferred. In our Newsbrief of 16 March 2015  we reported that the First Tier Tribunal decision meant that where a company succeeded to a trade carried on by a group company there was no requirement to stream. This confirmed our view of the law […]