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Corporation Tax Act 2010

Section 282: Valuation where disposal not sale at arm’s length

961.This section applies a market value price where oil is disposed of otherwise than at arm’s length, but where the disposal is not covered by the PRT rules. It is based on section 493(3), (5) and (6) of ICTA.

962.A common application of this rule is where oil is extracted from an oil field that is not within the scope of PRT following the reforms in FA 1993, which took fields given development consent on or after 16 March 1993 out of the scope of PRT.

963.This section also retains the term “person” because the transactions may not necessarily involve only companies.

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

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