SCHEDULES

SCHEDULE 15U.K.Oil activities: transferable tax history

PART 13 U.K.Onward sale

Application of paragraphs 83 to 90U.K.

81U.K.This Part applies if—

(a)the purchaser (referred to in this Part as “the first purchaser”) and the seller jointly make a TTH election (the “first TTH election”) in respect of an interest (the “first TTH asset”) in the TTH oil field,

(b)the first purchaser subsequently sells to another company (“the second purchaser”) an interest in a UK oil licence which applies to the area which includes the TTH oil field, and

(c)the first purchaser and the second purchaser jointly make a TTH election (the “subsequent TTH election”) in respect of an interest (the “subsequent TTH asset”) in the TTH oil field.

82(1)Sub-paragraph (2) applies if—U.K.

(a)the first purchaser has an interest in the UK oil licence referred to in paragraph 1, in addition to the interest in that licence acquired from the seller, and

(b)the UK oil licence referred to in paragraph 81(b) is the same UK oil licence referred to in paragraph 1.

(2)Interests in the licence acquired later by the first purchaser are treated, for the purposes of this Part, as being transferred to the second purchaser before interests in the licence acquired earlier by the first purchaser.