OT10810 | PRT: decommissioning certainty - PRT certificates and the release of taxpayer information

An expected benefit of the introduction of decommissioning relief deeds (DRDs) was to enable field participators to post decommissioning security on a post-tax basis. The participator should be able to obtain details of the Petroleum Revenue Tax (PRT) paid by themselves and other participators; present or past; so that the potential PRT repayments arising from the anticipated carry back of decommissioning losses can be taken into account when posting decommissioning security. FA13\S80(6) was introduced to facilitate this.

However, some decommissioning security agreements (DSAs) required the release of PRT data from HMRC beyond that permitted by FA13\S80(6). The text of a formal waiver has been agreed by HMRC and the Industry Representative Bodies.

New signatories to the DRD will now be invited; but not required; to sign a waiver allowing HMRC to release details of their PRT tax history to the other present and past participators in the field. HM Treasury will forward copies of signed waivers to the PRT team who will maintain a database. Existing signatories to DRDs were also invited to sign a waiver.

On receipt of a PRT certificate requiring details of the PRT paid on a chargeable period basis by other participators, HMRC will only issue a detailed certificate if the other participators (the third party companies) have signed a waiver. If any of these companies have not signed a waiver then a truncated certificate will be issued. That is a certificate that only contains the level of detailed information that HMRC can release in accordance with FA13\S80(6).