Taxation (International and Other Provisions) Act 2010 section 451

Oil and gas

Section 451 excludes oil and gas ring-fence income and related chargeable gains or losses from the corporate interest restriction calculations.

• Any amount that forms part of, or is used to calculate, a company's oil and gas ring-fence income must be left out of the interest restriction rules.
• Similarly, any aggregate chargeable gain or loss arising from disposals of interests in oil fields (ring-fence gains and losses) must also be excluded.
• Where a company is part of a worldwide group, just and reasonable adjustments must be made to the group's financial statements to give effect to these exclusions.
• The purpose of this exclusion is to ensure that the separate ring-fence tax regime for oil and gas activities is not distorted by the corporate interest restriction rules.