On April 20, 2017 the UK HM Treasury published a discussion paper titled: ‘Tax issues for late-life oil and gas assets’. By publishing the discussion paper, the UK government is seeking views on how the tax regime could better support getting older, ‘late-life’ assets into the hands of companies willing to invest in them. Next to publishing the discussion paper the UK government has also established a panel of upstream oil and gas experts to enable a detailed debate on the issues identified in that paper.

The UK government invites all interested parties to respond to the questions and points raised in the discussion paper. The HM Treasury states that it would be grateful if all responses are received by June 30, 2017.

 

The discussion paper

The discussion paper discusses a.o. the following subjects:

·   Chapter 1 Introduction

·   Chapter 2 The future of the UK Continental Shelf

·   Chapter 3 The oil and gas tax system and decommissioning

·   Chapter 4 How UKCS assets can be bought and sold

·   Chapter 5 Tax issues for late-life assets

o  Treatment of tax history

§   Issue 1: Determining transferred tax history

§   Issue 2: Possible restrictions on TTH

§   Issue 3: Order of TTH utilisation

§   Issue 4: Administration of TTH

§   Issue 5: Attribution of TTH

§   Issue 6: Tax treatment of sellers and TTH

§   Issue 7: Mandatory or optional system

o  Retained decommissioning and PRT

o  Treatment of losses on transfer of trade

·   Chapter 6 Next steps

 

Click here to be forwarded to the discussion paper ‘Tax issues for late-life oil and gas assets’ as available at the website of the HM Treasury, which will open in a new window.

 

Panel of upstream oil and gas experts

Next to publishing the discussion paper the UK government has also established a panel of upstream oil and gas experts to enable a detailed debate on the issues identified in that paper.

 

According to the HM Treasury the expert panel will consist of representatives from the following bodies:

·   HM Treasury (Chair)

·   HMRC

·   Oil & Gas Authority

·   BP

·   ConocoPhillips

·   CW Energy

·   EnQuest

·   Ernst & Young

·   ExxonMobil

·   Ineos

·   Oil & Gas UK

·   Premier Oil

·   Shell

·   Total

·   UK Oil Industry Tax Committee

 

Further information on the panel can be found here on the website of the HM Treasury.

 

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