Oil Taxation Act 1983 section Schedule 4 paragraph 6

Attribution of chargeable receipts to a foreign field

Schedule 4 paragraph 6 sets out the rules for determining which foreign field chargeable receipts should be attributed to when a participator has interests in one or more foreign fields.

  • Chargeable receipts are attributed to the foreign field for which expenditure on the relevant field asset would have been allowable under paragraph 3(1).
  • Where a participator has interests in more than one qualifying foreign field, the receipts are attributed to whichever field the asset would have been first used in connection with.
  • A special rule applies for assets that qualify as field assets only because of their connection to another field asset — their receipts follow the same attribution as the primary field asset they are linked to.
  • These rules ensure that each stream of chargeable receipts is matched to a single foreign field for tax purposes.

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