- 12 - provisions of the U.K. corporation tax generally applicable to U.K. corporate taxpayers. The Ring Fence Tax applies3 only to companies producing oil and gas and to related activities in the North Sea, and it erects a “ring fence” around oil and gas activities in the North Sea by requiring oil and gas companies to segregate income and expenses attributable to North Sea activity from income and expenses attributable to activity unrelated to the North Sea. The Ring Fence Tax was enacted under the U.K.’s sovereign taxing power, and under U.K. law it constitutes a tax on income. The Ring Fence Tax is structured as a corporate income tax. Along with other U.K. taxes such as the U.K. corporation income tax and the Ring Fence Tax, under U.K. law, PRT was intended, is structured, and is regarded as a tax. PRT was imposed unilaterally by the United Kingdom and was administered as a tax by the U.K. Inland Revenue. With regard to North Sea oil and gas recovery activities, the Ring Fence Tax and PRT are imposed in substitution for, and not in addition to, the generally applicable U.K. corporation tax. Oil and gas companies operating in the North Sea are liable, with regard to such activity, for the Ring Fence Tax and 3 In this Opinion, we often use the present tense to describe provisions of the Ring Fence Tax and PRT even though PRT was eliminated in 1993.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011