Corporation Tax Act 2010 section 291

Tariff receipts etc.

Section 291 ensures that tariff receipts earned by participators in oil fields are brought into the calculation of ring fence profits for corporation tax purposes, even where they would not otherwise be included.

• Where a participator in an oil field earns tariff receipts that are income in nature, those receipts are treated as income of the deemed separate ring fence trade, ensuring they fall within the ring fence corporation tax regime.
• Activities carried on by a participator (or a connected person) in making assets available to others in return for tariff payments are treated as oil extraction activities for the purposes of Part 8 of the Act.
• Where a tariff receipt is actually received by a person connected with the participator rather than the participator themselves, the connected person is treated as if they were a participator, so the receipt still falls within the ring fence trade.
• The definition of "tariff receipt" for this section follows section 291A and also encompasses anything treated as a tariff receipt or a tax-exempt tariffing receipt under the Oil Taxation Act 1983.

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