Exxon Corporation - Page 12




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          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.                                                         





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