- 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 fromPage: 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