Corporation Tax Act 2010 section 302

Interest on repayment of PRT or APRT

Section 302 provides that interest received by a participator in an oil field on a repayment of petroleum revenue tax (PRT) or advance petroleum revenue tax (APRT) is disregarded when calculating the participator's income for corporation tax purposes.

• When PRT paid by a participator is repaid with interest under Part 1 of the Oil Taxation Act 1975, the interest element is ignored for corporation tax.
• The same treatment applies to interest paid on advance petroleum revenue tax (APRT) that becomes repayable under Schedule 19 to the Finance Act 1982.
• In both cases, the interest received is completely disregarded when calculating the participator's taxable income for corporation tax.
• The effect is that a participator receiving a PRT or APRT repayment will not face a corporation tax charge on the interest component of that repayment.