Oil Taxation Act 1983 section 14

Re-opening of decisions for periods before the passing of this Act

Section 14 allows HMRC to re-open and adjust petroleum revenue tax (PRT) assessments for chargeable periods that ended before the Oil Taxation Act 1983 was passed, so that those earlier periods can be recalculated to reflect the new expenditure relief rules introduced by the Act.

• Where the 1983 Act changes the amount of allowable expenditure or relief available for a chargeable period that ended before the Act was passed, HMRC may re-open the assessment for that period to give effect to the change.
• This re-opening power applies even if the normal time limits for amending assessments under the Oil Taxation Act 1975 would otherwise have expired.
• Any adjustments made under this provision follow the same procedural rules as other PRT amendments, including rights of appeal, except that normal statutory time limits do not act as a bar.
• The provision was subsequently amended by the Finance Act 2009 (Schedule 45, paragraph 2(4)) to align it with updated HMRC review and appeal procedures.

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