SCHEDULES

SCHEDULE 32U.K. PETROLEUM REVENUE TAX: UNRELIEVABLE FIELD LOSSES

Extent to which losses to be relievedU.K.

8(1)Where the interest in the field of a different owner is the transferred interest, the intermediate unrelieved loss is to be relieved against the whole of any relevant profits accruing to the different owner.

(2)Where the interest in the field of a different owner is part of the transferred interest, the corresponding part (but only that part) of the intermediate unrelieved loss is to be relieved against the whole of any relevant profits accruing to the different owner.

(3)Where—

(a)a different owner’s interest in the field includes the transferred interest, but

(b)the transferred interest is only part of the different owner’s interest in the field,

the intermediate unrelieved loss is to be relieved against the corresponding part (but no other part) of any relevant profits accruing to the different owner.

(4)Sub-paragraph (5) applies where—

(a)a different owner’s interest in the field includes part only of the transferred interest (“the owned part of the transferred interest”), and

(b)the owned part of the transferred interest is only part of the different owner’s interest in the field.

(5)Only the part of the intermediate unrelieved loss corresponding to the owned part of the transferred interest is to be relieved, and it is to be relieved against (but only against) the part of any relevant profits accruing to the different owner that corresponds to the part which the owned part of the transferred interest forms of the different owner’s interest in the field.