Oil and gas company: gains subject to the supplementary charge
In Wintershall (E&P) v HMRC [2015] UKUT 334 (23 June 2015) the UT found that a gain realised by an oil and gas company on the disposal of a North Sea interest was subject to the supplementary charge.
Wintershall’s activity was the development and production of oil and gas. It had realised a gain of over £6m on the disposal of an interest in the North Sea. The gain was part of Wintershall’s ‘ring fence profits’ and the issue was whether it was also part of its ‘adjusted ring fence profits’ subject to a supplementary charge under ICTA 1988 s 501A(1).
Adopting a purposive interpretation of the provisions the UT noted in particular that for corporation tax purposes the word ‘profits’ means ‘income and chargeable gains’ (ICTA 1988 s6(4)(a)). Where the words used had such...
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Oil and gas company: gains subject to the supplementary charge
In Wintershall (E&P) v HMRC [2015] UKUT 334 (23 June 2015) the UT found that a gain realised by an oil and gas company on the disposal of a North Sea interest was subject to the supplementary charge.
Wintershall’s activity was the development and production of oil and gas. It had realised a gain of over £6m on the disposal of an interest in the North Sea. The gain was part of Wintershall’s ‘ring fence profits’ and the issue was whether it was also part of its ‘adjusted ring fence profits’ subject to a supplementary charge under ICTA 1988 s 501A(1).
Adopting a purposive interpretation of the provisions the UT noted in particular that for corporation tax purposes the word ‘profits’ means ‘income and chargeable gains’ (ICTA 1988 s6(4)(a)). Where the words used had such...
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