Exxon Corporation - Page 16




                                       - 16 -                                         
               (5)  An exemption from PRT is allowed for revenue relating             
               to North Sea natural gas production derived from pre-July              
               1975 contracts with the British Gas Corporation;                       
               (6)  Upon abandoning fields, carryover of unused losses                
               are allowed without limit to other North Sea fields;                   
               (7)  PRT was enacted as a “prior charge” to the Ring                   
               Fence Tax which means that PRT is computed, assessed,                  
               and paid before the Ring Fence Tax, and PRT is                         
               deductible in computing the Ring Fence Tax;                            
               (8)  Of the limited types of expenses that are not allowed             
               as deductions for PRT purposes, interest expense is the only           
               nonallowable expense that is significant, and in lieu of               
               interest expense, a deduction is allowed for “uplift”                  
               (discussed further, infra).                                            

               Because of the above features of PRT, activities in a North            
          Sea field generally are not subject to PRT until they reflect a             
          cumulative profit.                                                          
               PRT liability of a company is to be paid only in cash, not             
          in kind.                                                                    
               On a number of occasions, in response to changes in world              
          oil markets and in order to make certain adjustments to PRT,                
          provisions of PRT were amended by the United Kingdom.  Such                 
          amendments that, over the years, have been made to PRT are not              
          particularly significant to the issue before us and generally are           
          not described herein.                                                       
               As indicated, in order to minimize PRT avoidance through               
          intercompany interest charges, interest expense deductions                  
          relating to North Sea oil and gas recovery activities are not               
          allowed in computing PRT liability.  Current deductions from                





Page:  Previous  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  Next

Last modified: May 25, 2011