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Finance Act 1999 (c. 16)(The document as of February, 2008) Page 6 Pages: P.1 | P.2 | P.3 | P.4 | P.5 | P.6 | P.7 | P.8 | P.9 | P.10 | P.11 | P.12 | P.13 | P.14 | P.15 | P.16 | P.17 | P.18 (6) If an amount is paid to the member at any time under the arrangement, he shall be treated as disposing of the whole asset or, as the case may be, part of the asset at that time for a consideration equal to that amount. (7) If syndicate rights held by the member otherwise than under the arrangement become at any time rights held by him under the arrangement, he shall be treated as disposing of those rights at that time for a consideration equal to their market value at that time. (8) If syndicate rights held by the member under the arrangement become at any time rights held by him otherwise than under the arrangement, he shall be treated as acquiring those rights at that time for a consideration equal to their market value at that time. (9) Nothing in subsection (3) above shall affect the operation of section 24(1) of the [1992 c. 12.] Taxation of Chargeable Gains Act 1992 (disposals where assets extinguished etc.) in relation to the asset. (10) Subject to subsection (11) below this section applies to arrangements entered into on or after 6th April 1999 or subsisting on that date. (11) In the case of arrangements subsisting on 6th April 1999, this section has effect-- (a) as if the time mentioned in subsection (3) above were the earliest time ("the notional time of acquisition") at which the member acquired any of the syndicate rights held by him under the arrangement immediately before 6th April 1999; (b) as if the consideration referred to in subsection (4) above were the consideration, in money or money's worth, given by him wholly and exclusively for the acquisition of such of those rights as he acquired at the notional time of acquisition; and (c) in relation to times before 6th April 1999, as if the amount mentioned in subsection (5) above were the amount of any consideration, in money or money's worth, given by him wholly and exclusively for the acquisition, after the notional time of acquisition, of rights such as are mentioned in paragraph (a) above; and the incidental costs of any acquisition falling within paragraph (b) or (c) above shall be taken to be incidental costs of the acquisition of the asset. 83 Provisions supplementary to s. 82(1) In section 82 above and this section, except where the context otherwise requires--
(2) The conditions mentioned in paragraph (ii) of the above definition of "members' agent pooling arrangement" are that under the arrangement-- (a) the member must participate in each of the syndicates to which the arrangement relates; and (b) the extent to which the member participates in each such syndicate is determined-- (i) by the members' agent; or (ii) according to a formula provided for in the arrangement. (3) References in section 82 above to the payment of an amount are references to the payment of an amount in money or money's worth; and to the extent that an amount mentioned in subsection (4), (5) or (6) of that section is paid in money's worth, the amount of the consideration or expenditure there referred to shall be calculated by reference to the market value of the money's worth at the time of the payment mentioned in that subsection. (4) Section 82 above and this section have effect in relation to a Scottish partnership which is an underwriting member of Lloyd's as they have effect in relation to a member, but as if the reference in section 82(2) to any liability of the member's to capital gains tax that may arise from transactions effected in pursuance of the arrangement were a reference to any such liability of members of the partnership that may so arise. 84 Lloyd's: roll-over relief(1) In section 155 of the [1992 c. 12.] Taxation of Chargeable Gains Act 1992 (classes of assets for the purposes of roll-over relief), after Class 7 there shall be inserted-- " CLASS 8 Assets within heads A and B below.Head ARights of a member of Lloyd's under a syndicate within the meaning of Chapter III of Part II of the [1993 c. 34.] Finance Act 1993. Head BAn asset which a member of Lloyd's is treated as having acquired by virtue of section 82 of the Finance Act 1999. " (2) This section applies to-- (a) assets (or interests in them) disposed of on or after 6th April 1999; (b) assets (or interests in them) acquired on or after that date. Advance pricing agreements and CFCs85 Advance pricing agreements etc(1) This section applies in relation to any chargeable period where-- (a) the Board have made a written agreement with any person ("the taxpayer"); (b) the agreement relates to one or more of the matters mentioned in subsection (2) below and to that chargeable period; (c) the agreement is one made as a consequence of an application by the taxpayer to the Board for the clarification by agreement of the effect in the taxpayer's case of provisions by reference to which questions relating to any one or more of those matters fall, or might fall, to be determined; and (d) the agreement contains a declaration that it is an agreement made for the purposes of this section. (2) Those matters are-- (a) the attribution of income to a branch or agency through which the taxpayer has been carrying on a trade in the United Kingdom, or is proposing so to carry on a trade; (b) the attribution of income to any permanent establishment of the taxpayer (wherever situated) through which he has been carrying on, or is proposing to carry on, any business; (c) the extent to which income which has arisen or may arise to the taxpayer is to be taken for any purpose to be income arising in a country or territory outside the United Kingdom; (d) the treatment for tax purposes of any provision made or imposed (whether before or after the date of the agreement) as between the taxpayer and any associate of his; (e) the treatment for tax purposes of any provision made or imposed (whether before or after the date of the agreement) as between a ring fence trade carried on by the taxpayer and any other activities so carried on. (3) Subject to the following provisions of this section and to section 86 below, the Tax Acts shall have effect in the taxpayer's case as if questions relating to the matters mentioned in subsection (2) above were, to the extent provided for in the agreement, to be determined in accordance with the agreement, and without reference to the provisions in accordance with which they would otherwise have fallen to be determined. (4) In the case of so much of any question as-- (a) relates to any matter mentioned in paragraph (d) or (e) of subsection (2) above, and (b) is not comprised in a question falling within another paragraph of that subsection, the provisions reference to which is capable of being excluded under subsection (3) above by an agreement made for the purposes of this section shall be confined to those contained in Schedule 28AA to the Taxes Act 1988 (transfer pricing rules). (5) Any such application to the Board as is mentioned in subsection (1)(c) above must set out-- (a) the taxpayer's understanding of what would, in his case, be the effect, in the absence of any agreement, of the provisions in relation to which clarification is sought; (b) the respects in which it appears to the taxpayer that clarification is required in relation to those provisions; and (c) how the taxpayer proposes that matters should be clarified in a manner consistent with the understanding mentioned in paragraph (a) above. (6) For the purposes of this section two persons are associates, in relation to provision made or imposed as between them if, within the meaning of Schedule 28AA to the Taxes Act 1988-- (a) one of them is directly or indirectly participating, at the time of the making or imposition of the provision, in the management, control or capital of the other; or (b) the same person or persons is or are, at that time, directly or indirectly participating in the management, control or capital of each of the two persons; and, in the case of provision made or imposed by or in relation to the terms of any sale of oil (within the meaning of paragraph 9 of that Schedule), two persons shall also be treated as associates for the purposes of this section wherever sub-paragraph (2) of that paragraph would require them for the purposes of that Schedule to be treated in relation to that provision as falling within paragraph (b) above. (7) In this section "ring fence trade", in relation to the taxpayer, means any activities which-- (a) are carried on by the taxpayer as, or as part of, a trade; and (b) in accordance with section 492(1) of the Taxes Act 1988 (tax treatment of oil extraction activities), either-- (i) fall to be treated for tax purposes as a separate trade, distinct from all other activities carried on by the taxpayer; or (ii) would so fall if the taxpayer did carry on any other activities as part of that trade. (8) This section applies in relation to any chargeable period ending on or after the day on which this Act is passed but only if the agreement is one made on or after that day and in relation to that period. 86 Provisions supplementary to s. 85(1) The chargeable periods in relation to which provision may be made by a section 85 agreement include periods ending before the making of the agreement. (2) An agreement shall not have effect in accordance with section 85(3) above in relation to any determination of a question which-- (a) relates to a time after a time as from which an officer of the Board has revoked the agreement in accordance with its terms; (b) relates to a time after or in relation to which there has been a failure by a party to the agreement to comply with any provision of the agreement compliance with which is, under the terms of the agreement, to be a condition of its having effect; or (c) relates to any matter as respects which any other conditions which, by the terms of the agreement, are to be conditions of its having effect have not been, or are no longer, satisfied. (3) Where-- (a) there is a section 85 agreement between the Board and any person, and (b) there is a mutual agreement made under and for the purposes of any double taxation arrangements which is not consistent with the terms of the section 85 agreement, it shall be the duty of the Board to ensure that all such modifications of the section 85 agreement are made (whether in exercise of powers conferred on the Board by that agreement or otherwise) as may be necessary for enabling effect to be given to the mutual agreement in relation to the subject-matter of the section 85 agreement. (4) It shall be the duty of any person who is a party to a section 85 agreement to provide the Board from time to time with all such reports and other information as he may be required to provide under the agreement or by virtue of any request made by an officer of the Board in accordance with the terms of the agreement. (5) Where-- (a) the Board and any person have purported to enter into a section 85 agreement at any time, (b) before that time, that person fraudulently or negligently provided the Board with information which was false or misleading, (c) that information was so provided for or in connection with the application to the Board for the making of the agreement or otherwise in connection with its preparation, and (d) the Board have notified that person that the agreement is nullified by reason of the misrepresentation, the agreement shall be deemed never to have been made. (6) Any provision of a section 85 agreement that provides for the modification or revocation of that agreement by the Board, or by an officer of the Board, may provide for the modification or revocation to take effect as from such time (including a time before the modification is made or the agreement revoked) as the Board or officer may determine. (7) Where a section 85 agreement-- (a) relates to a chargeable period beginning or ending before the making of the agreement, and (b) provides for the manner in which adjustments are to be made for tax purposes in consequence of that agreement, the adjustments shall be made for those purposes in the manner provided for in the agreement. (8) A person shall be liable to a penalty not exceeding £10,000 if he fraudulently or negligently makes any false or misleading statement to the Board or an officer of the Board either-- (a) for or in connection with any application to the Board for them to enter into a section 85 agreement; or (b) otherwise in connection with the preparation of such an agreement. (9) In section 98 of the [1970 c. 9.] Taxes Management Act 1970 (penalties in connection with returns etc.), in the second column of the table, after the final entry there shall be inserted the following entry--
(10) In this section--
87 Effect of section 85 agreements on non-parties(1) This section applies where-- (a) any agreement made for the purposes of section 85 above has effect in relation to any provision ("the actual provision") made or imposed as between any person ("the taxpayer") and another ("the other party"); and (b) section 85(3) above has the effect in the taxpayer's case of requiring a question relating to the actual provision to be determined in accordance with the agreement rather than by reference to rules which would otherwise be applicable by virtue of Schedule 28AA to the Taxes Act 1988. (2) Paragraphs 6 and 7 of Schedule 28AA to the Taxes Act 1988 (relief from double counting in the case of disadvantaged persons) shall have effect in the other party's case on the assumption that any question falling within subsection (3) below is to be determined, to the same extent as in the taxpayer's case, by reference to the agreement. (3) Those questions are-- (a) whether the taxpayer is a person on whom a potential advantage in relation to United Kingdom taxation is conferred by the actual provision; and (b) what constitutes the arm's length provision in relation to the actual provision. (4) Subsection (2) above shall have effect subject to any agreement made for the purposes of section 85 above between the Board and the other party. (5) Section 111 of the [1998 c. 36.] Finance Act 1998 (notice to persons who may be entitled to claim as disadvantaged persons) shall have effect as if the assumptions referred to in subsection (1)(b) of that section included any assumptions falling to be made by virtue of the agreement. 88 Controlled foreign companies(1) In Schedule 25 to the Taxes Act 1988 (cases where section 747(3) does not apply), after sub-paragraph (1A) of paragraph 2 (acceptable distribution policy) there shall be inserted the following sub-paragraph-- " (1B) A dividend paid by a company shall not fall within sub-paragraph (1)(d) above if, and to the extent that, the profits which are the relevant profits in relation to the dividend derive from dividends or other distributions paid to the company at any time which are dividends or other distributions-- (a) to which section 208 applied; or (b) to which that section would have applied if the company had been resident in the United Kingdom at that time.
(2) Subsection (1) above applies for the purpose of determining whether dividends paid on or after 9th March 1999 for accounting periods ending on or after that date fall within sub-paragraph (1)(d) of paragraph 2 of that Schedule. Management and enforcement89 Corporation tax: due and payable date(1) In the Table in section 98 of the [1970 c. 9.] Taxes Management Act 1970 (penalties for failure to provide information, produce documents etc.), in the first column, after the entry for Part III of the Taxes Management Act 1970 insert "regulations under section 59E of this Act;". (2) In section 102(5)(a) of the [1989 c. 26.] Finance Act 1989 (surrender of company tax refund within group), for "section 10 of the Taxes Act 1988" substitute "section 59D or 59E of the Taxes Management Act 1970". (3) This section has effect in relation to accounting periods ending on or after 1st July 1999. 90 Release or writing off of debt: interest on tax overpaid(1) In section 826(4) of the Taxes Act 1988 (interest on tax overpaid)-- (a) for "the repayment of, or of the part in question of, the loan or advance mentioned in section 419(4) was made" substitute "the event giving rise to entitlement to relief under section 419(4) occurred"; and (b) in paragraph (a)(i) of that subsection, after "repayment" insert ", or the release or writing off,". (2) This section has effect in relation to the release or writing off of the whole or part of a debt on or after 6th April 1999. 91 Advance corporation tax: consequences of abolition(1) Schedule 16 to the Taxes Act 1988 (collection of income tax on company payments) is amended as follows. (2) In paragraph 4 (payment of tax), omit-- (a) in sub-paragraph (1), the words "Subject to sub-paragraph (3) below,"; and (b) sub-paragraph (3). (3) In paragraph 8 (items included in return or claim in error)-- (a) for "should have been included in a return under Schedule 13" substitute "should not have been so included"; and (b) for "been included in the right return" substitute "not been included in the return or claim in question". (4) In section 32(6) of the [1998 c. 36.] Finance Act 1998 (meaning of "unrelieved surplus advance corporation tax"), for "paragraph 11" substitute "paragraph 12". (5) Subsections (1) to (3) above have effect-- (a) in relation to periods for which a return is required under paragraph 2 of Schedule 16 to the Taxes Act 1988 beginning on or after 6th April 1999; and (b) in relation to accounting periods beginning on or after that date. (6) The amendment made by subsection (4) above shall be deemed always to have had effect. 92 Group relief: consequences of reduction in surrenderable amount(1) Part VIII of Schedule 18 to the Finance Act 1998 (claims for group relief) is amended as follows. (2) In paragraph 75 (reduction in amount available for surrender by way of group relief)-- (a) in sub-paragraph (1), for "amount available for relief" substitute "total amount available for surrender"; and (b) in sub-paragraphs (2) and (4), before "amount available for surrender" insert "total". (3) After that paragraph insert-- " Assessment on other claimant companies75A (1) This paragraph applies where, after the surrendering company has given notice of consent to surrender, a claimant company ("the chargeable company") has become liable to tax in consequence of receiving-- (a) notice of the withdrawal of consent, or a copy of a new notice of consent, under paragraph 75(3), or (b) a copy of a notice containing directions by the Inland Revenue under paragraph 75(4). (2) If any of the tax is unpaid six months after the chargeable company's time limit for claims, the Inland Revenue may make an assessment to tax in the name of the chargeable company on any other company that has obtained group relief as a result of the surrender. (3) The assessment may not be made more than two years after that time limit. (4) The amount of the assessment must not exceed-- (a) the amount of the unpaid tax, or (b) if less, the amount of tax which the other company saves by virtue of the surrender. (5) A company assessed to an amount of tax under sub-paragraph (2) is entitled to recover from the chargeable company-- (a) a sum equal to that amount, and (b) any interest on that amount which it has paid under section 87A of the [1970 c. 9.] Taxes Management Act 1970 (interest on unpaid corporation tax). (6) For the purposes of this paragraph the chargeable company's time limit for claims is the last of the dates mentioned in paragraph 74(1) on which the chargeable company could make or withdraw a claim for group relief for the accounting period for which the claim in question is made. " (4) In paragraph 76 (assessments to recover excessive group relief), after sub-paragraph (2) add-- " (3) If an assessment under this paragraph is made because a claimant company fails, or is unable, to amend its company tax return under paragraph 75(6), the assessment is not out of time if it is made within one year from-- (a) the date on which the surrendering company gives notice of the withdrawal of consent, or (if later) sends a copy of a new notice of consent, to the claimant company under paragraph 75(3), or (b) the date on which the Inland Revenue send the claimant company a copy of a notice containing their directions under paragraph 75(4). " (5) In section 87A(3) of the Taxes Management Act 1970 (interest on unpaid corporation tax assessed on other persons), for "section 96(8) of the [1990 c. 29.] Finance Act 1990" substitute "paragraph 75A(2) of Schedule 18 to the [1998 c. 36.] Finance Act 1998". (6) Section 96 of the Finance Act 1990 shall cease to have effect. (7) This section has effect in relation to accounting periods ending on or after 1st July 1999. 93 Company tax returns, etc(1) The enactments mentioned in Schedule 11 to this Act have effect with the amendments specified there, which are minor amendments and amendments consequential on Schedule 18 to the Finance Act 1998 (company tax returns, assessments and claims, etc.). (2) The amendments made by Schedule 11 to this Act have effect in relation to accounting periods ending on or after 1st July 1999. Part IV Oil Taxation94 Excluded oil(1) This section applies where-- (a) a contract ("the old contract") provides for the sale by a person ("A") of oil consisting of gas to the British Gas Corporation or one of its successors ("the purchaser"); (b) the old contract is a contract made, or treated (by virtue of this section) as made, before the end of June 1975; (c) the old contract is replaced by a contract ("the new contract") for the sale of oil consisting of gas to the purchaser made after the end of June 1975; and (d) any of the rights and liabilities which, under the old contract, were rights and liabilities of A are, under the new contract, rights and liabilities of another person ("B"). (2) The new contract shall be treated for the purposes of section 10(1)(a) of the [1975 c. 22.] Oil Taxation Act 1975 as the same contract as the old contract unless the rights and liabilities of B under the new contract are so different from those of A under the old contract that a contract conferring those rights and imposing those liabilities on A could not have been regarded as the same contract as the old contract. (3) For the purposes of subsection (1) above the successors of the British Gas Corporation are-- (a) British Gas plc; and (b) British Gas Trading Limited. (4) This section shall be deemed always to have had effect. 95 Sale and lease-back(1) This section applies to a lease ("the lease in question") of an asset ("the relevant asset") where-- (a) a person ("the seller") who is a participator in an oil field ("the seller's oil field") has made a disposal in a chargeable period of the relevant asset or an interest in it; (b) the relevant asset was a qualifying asset in relation to the seller and the seller's oil field is the chargeable field in relation to it; (c) the relevant asset is used in connection with an oil field ("the lessee's oil field") by a participator in that field ("the lessee") under the lease in question; (d) the seller, or a person connected with him at any time in the relevant period, is the lessee; and (e) the lessee uses the relevant asset before the end of the period of two years beginning with the disposal. (2) Subject to subsection (8) below, to the extent that the expenditure falling within subsection (3) below exceeds the amount of the cap, that expenditure shall not be allowable under section 3 or 4 of the principal Act or section 3 of the [1983 c. 56.] Oil Taxation Act 1983 for the lessee's oil field. (3) That expenditure is the aggregate of the following-- (a) the total expenditure, excluding operating expenditure, incurred by the lessee under the lease in question; and (b) if at any time after the disposal he acquires the relevant asset or an interest in it, the total expenditure (not falling within paragraph (a) above) incurred by him in acquiring the asset or interest. (4) Subject to subsections (5) to (7) below-- (a) if the period in which the disposal was made is one in which the seller has benefitted from safeguard relief, the amount of the cap is the smaller of-- (i) the amount given by dividing the marginal tax on the disposal receipts by the applicable rate of tax; and (ii) the amount of the disposal receipts; and (b) in any other case the amount of the cap is the amount of the disposal receipts. (5) Subject to subsection (7) below, where at the relevant time there are, in relation to the relevant asset, two or more leases to which this section applies, the amount of the cap for the lease in question shall be the appropriate proportion of the cap found by applying subsection (4) above. (6) For the purposes of subsection (5) above the appropriate proportion is the proportion given by the formula-- ---where--
(7) Where at the relevant time the relevant asset is used, or is expected to be used, by the lessee under the lease in question in connection with two or more oil fields, the amount of the cap for each of the fields shall be so much of the cap found by applying subsections (4) to (6) above as accords with the proportion of the use of the asset under the lease that is expected, at that time, to be-- (a) use in connection with that field; or (b) use giving rise to tariff receipts of the lessee attributable to that field. (8) Where-- (a) expenditure falling within subsection (3) above has been allowed for the lessee's oil field, on a claim under Schedule 5 or 6 to the principal Act, on the basis that the cap was of a particular amount; (b) information later becomes available to the Board which establishes that the cap is not of that amount; and (c) the amount that was allowed exceeds the amount (if any) of the expenditure falling within that subsection that would have been allowed on the claim if the information had been available when the expenditure was allowed, the excess shall continue to be allowable. (9) Subject to subsection (10) below, this section and sections 96 and 97 below apply to assets, or interests in assets, disposed of on or after 9th March 1999. (10) This section and those sections do not apply to assets, or interests in assets, disposed of pursuant to an agreement made before that date if-- (a) the agreement is not conditional; or (b) the agreement is conditional and the condition is satisfied before that date. 96 Transfer of field interest(1) This section applies where-- (a) section 95 above has applied to a lease; (b) the lessee has transferred the whole or part of his interest in the lessee's oil field; and (c) pursuant to the transfer, the relevant asset is used in connection with that oil field under a lease ("the new participator's lease") by the person who is the new participator in relation to the transfer. (2) Subject to subsection (4) below, section 95 above shall have effect as if the new participator were the lessee and the new participator's lease were the lease in question. (3) The reference in subsection (1)(b) above to the lessee includes a reference to a successor of his; and subject to subsection (4) below, the expenditure that the new participator is treated by virtue of subsection (2) above as having incurred includes-- (a) any expenditure, excluding operating expenditure, incurred by the lessee or a successor of his under the lease in question or a lease of the relevant asset; and (b) any expenditure (not falling within paragraph (a) above) incurred by the lessee or a successor of his after the disposal mentioned in section 95(1)(a) above in acquiring the relevant asset or an interest in it. (4) Where the transfer mentioned in subsection (1)(b) above, or any antecedent transfer, was a transfer of part of the transferor's interest in the lessee's oil field-- (a) the amount of the cap which is applicable by virtue of subsection (2) above shall be so much of the cap that would be applicable apart from this subsection as accords with the proportion of the lessee's interest in the field that is represented by the new participator's interest in the field; and (b) the expenditure incurred (as mentioned in subsection (3) above) by the lessee or any successor of his that is treated, by virtue of subsection (2) above, as expenditure incurred by the new participator shall be so much of the expenditure incurred (as so mentioned) by the person concerned as accords with the proportion of that person's interest in the field that is represented by the new participator's interest in the field. (5) A person is a successor of the lessee for the purposes of this section if and only if-- (a) this section has applied to an earlier transfer by the lessee or a successor of his of the whole or part of his interest in the lessee's oil field; and (b) that person was the new participator in relation to the earlier transfer and used the relevant asset under the lease in connection with that oil field. (6) In this section "antecedent transfer" means a transfer (other than the transfer mentioned in subsection (1)(b) above) by the lessee or a successor of his of the whole or part of his interest in the lessee's oil field, pursuant to which the relevant asset was used as mentioned in subsection (1)(c) above. 97 Provisions supplementary to ss. 95 and 96(1) For the purposes of section 95 above the marginal tax on the disposal receipts is the difference between-- (a) the amount of tax to which the seller is chargeable on the assessable profit accruing to him from the seller's oil field in the period in which the asset or interest was disposed of; and (b) the amount of tax to which the seller would have been so chargeable if the amount or value of the consideration received or receivable by him in respect of the disposal in that period of the asset or interest had been nil. (2) For the purposes of that section-- (a) any question whether a person is connected with the seller shall be determined in accordance with the provisions of section 839 of the Taxes Act 1988; (b) the relevant period is the period beginning with the time of the disposal of the asset or interest and ending with the time when the first claim is made for the allowance, for the lessee's oil field, of expenditure incurred by the lessee or a successor of his under the lease in question or a lease of the relevant asset (and in this paragraph the reference to the lessee includes a reference to a person who is treated as the lessee by virtue of section 96 above); (c) the applicable rate of tax is the rate at which tax is charged under section 1(2) of the principal Act at the time of the disposal of the asset or interest; (d) the amount of the disposal receipts is the aggregate of the amount or value of any consideration received or receivable by the seller in respect of the disposal of the asset or interest; (e) a chargeable period is a period in which the seller benefits from safeguard relief if and only if the tax payable by the seller for that period is less than it would have been if section 9 of the principal Act (safeguard relief) had not been enacted; (f) the relevant time is the end of the earliest claim period for which a claim such as is mentioned in paragraph (b) above is made; and (g) tariff receipts of the lessee shall be taken to be attributable to an oil field if and only if they are attributable to the field for any chargeable period for the purposes of the [1983 c. 56.] Oil Taxation Act 1983. (3) In section 96 above references-- (a) to the transfer by a person of the whole or part of his interest in the lessee's oil field; or (b) in relation to a transfer, to the new participator, shall be construed in accordance with Schedule 17 to the [1980 c. 48.] Finance Act 1980. (4) The expenditure which for the purposes of sections 95 and 96 above shall be taken to be operating expenditure shall be so much of the expenditure incurred by the lessee or, as the case may be, a successor of his under the lease concerned as appears, on a just and reasonable estimate, to be operating expenditure. Pages: P.1 | P.2 | P.3 | P.4 | P.5 | P.6 | P.7 | P.8 | P.9 | P.10 | P.11 | P.12 | P.13 | P.14 | P.15 | P.16 | P.17 | P.18 -- Back --
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