The Court of Appeal has decided, in Total, that companies which would be disadvantaged by a time based apportionment of oil related profits for the purposes of the supplementary charge could elect for a different profit apportionment method, even if their profits were uneven only because of common (rather than exceptional) industry factors. The court also applied a more flexible approach to assessing alternative methods than the Upper Tribunal had. The decision may be relevant to other apportionment provisions.
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The Court of Appeal has decided, in Total, that companies which would be disadvantaged by a time based apportionment of oil related profits for the purposes of the supplementary charge could elect for a different profit apportionment method, even if their profits were uneven only because of common (rather than exceptional) industry factors. The court also applied a more flexible approach to assessing alternative methods than the Upper Tribunal had. The decision may be relevant to other apportionment provisions.
If you are not a subscriber, subscribe now to read this content.
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