15 Sep 2022
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. https://cwenergy.co.uk/ We are now looking forward to developing the business as an independent […]
Read More...31 Aug 2022
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 […]
Read More...14 Jul 2022
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 (https://cwenergy.co.uk/energy-profits-levy-draft-legislation-published-for-consultation/) 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 […]
Read More...22 Jun 2022
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 […]
Read More...26 May 2022
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 […]
Read More...23 Mar 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 […]
Read More...14 Mar 2022
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: https://cwenergy.co.uk/scope-of-the-ring-fence-royal-bank-of-canada-case 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 […]
Read More...09 Feb 2022
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 https://cwenergy.co.uk/potential-changes-to-taxation-of-profits-for-multinational-groups 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 […]
Read More...25 Jan 2022
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 https://cwenergy.co.uk/notification-of-uncertain-tax-treatments-draft-legislation-published/ 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 […]
Read More...27 Oct 2021
The Chancellor delivered the Autumn Budget and Spending Review 2021 today. We set out below the key announcements that apply to the corporate sector, although no new measures are of direct relevance to the oil and gas sector. Ring fence and supplementary charge to corporation tax rates Despite the rise in the main tax rate as discussed below, there was no specific announcement on any changes to the oil tax rates. Therefore, the rates will continue to be those currently […]
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