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Based on industry data that is in evidence and that was
gathered from Exxon and approximately 33 other oil companies
involved in North Sea oil and gas production, the cumulative
total uplift allowed the companies for 1975 through 1988 was
�12.4 billion, as compared to cumulative total interest expense
not allowed the companies under PRT of �8.6 billion. In the
Appendix to this Opinion, for 1975 through 1988, we set forth the
amount of uplift and other deductions allowed to Exxon and to the
other oil and gas companies and the amount of ring fence interest
expense not allowed to Exxon and the other oil and gas companies
in the computation of PRT liability.
As a result of the special allowances such as oil, tariff
receipts, safeguard, and uplift, PRT represents and constitutes a
tax on a subset of net income subject to the Ring Fence Tax.
Through 1992, Exxon had interests in 23 oil-producing North
Sea fields, but significant PRT was paid only with regard to five
of the fields (Brent, Forties, Dunlin, Fulmar, and North
Cormorant). More than 60 percent of total PRT paid by Exxon
through 1992 was paid with respect to only one field -- the Brent
field which was the highest oil-producing field in the North Sea.
Generally for the industry, the bulk of PRT was paid with
respect to a limited number of the largest and most profitable
fields. More specifically, through 1988, approximately 75
percent of total cumulative PRT collected by the United Kingdom
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