168 Expenditure on plant or machinery incurred by contractorU.K.
(1)This section applies if—
(a)the contractor incurs capital expenditure on the provision of plant or machinery of a description specified in the contract,
(b)the plant or machinery is to have an oil-related use under the contract, for the purposes of a trade of oil extraction carried on by the contractor,
(c)the amount of the expenditure is commensurate with the value of the contractor’s interest under the contract, and
(d)the plant or machinery is transferred to the government or representative in accordance with the contract.
(2)Despite the transfer, the plant or machinery is to be treated for the purposes of this Part as owned by the contractor (and not by any other person) until—
(a)it ceases to be owned by the government or representative, or
(b)it ceases to be used, or held for use, by any person under the contract.
This is subject to section 170(2).