Corporation Tax Act 2010 section 332DB

Restriction where project in additionally-developed field qualified for field allowance

Section 332DB restricts the amount of investment allowance that can be generated from expenditure on projects in oil fields that were classified as additionally-developed fields before 1 April 2015, by capping relief at a threshold linked to the old field allowance for that project.

  • Expenditure on projects in fields that were additionally-developed before 1 April 2015 is only relievable for investment allowance purposes once cumulative spending exceeds a threshold equal to 160% × the original field allowance × the company's share of project-related reserves
  • The cumulative total of relevant expenditure is calculated from 1 April 2015 onwards, adjusted for any disposals or acquisitions of shares in the project-related reserves
  • The restriction does not apply to expenditure incurred on or after the date the OGA determines the project was materially completed
  • The restriction also does not apply where the company holds no share of project-related reserves and the expenditure relates to making an asset available in a way that generates tariff receipts or tax-exempt tariffing receipts

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