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Corporation Tax Act 2010

Section 291: Tariff receipts etc

995.This section brings certain tariff receipts into the calculation of ring fence profits if those receipts would not otherwise be included. It is based on section 496 of ICTA.

996.The corresponding rule for income tax is section 225M of ITTOIA (inserted by Schedule 1 to TIOPA).

997.Tariff receipts arise where assets used in the ring fence trade are not used wholly for oil extraction by the owner but are used by other businesses in return for payment of a fee or “tariff”. Typical examples include the use of pipelines and treatment plants.

998.Tax-exempt tariffing receipts arise where the oil field to which the assets are attached for PRT purposes is not within the charge to PRT and therefore the tariffs are not chargeable to PRT.

999.Definitions of “tariff receipt” and “tax-exempt tariffing receipt” have been included to aid users of the legislation.

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