In MCX Dunlin (UK) Ltd v HMRC [2020] EWHC 11 (Ch) (13 January 2020) the High Court held that interest was due on repayments of liabilities to petroleum revenue tax (PRT) dating from the 1980s which had been met by crediting advance PRT (APRT).
The company acquired the Dunlin oil field in 2007 and incurred substantial losses on winding down the production of oil from the field which were allowable under the PRT regime. HMRC carried the losses back against profits made in earlier years by the previous participators in the field and substantial repayments were made to them. Under the terms of the agreement by which the oil field was transferred the previous participators then passed the repayments on to the company.
To the extent that the previous participators had paid the PRT in cash the repayments were made with interest. To the extent however that the PRT liability was met by crediting APRT under rules that applied from 1982 to 1987 ...
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