SolvedOT18132 | PRT: transfer of licence interests - terminal losses: example 2
From HM Revenue & Customs · Oil Taxation Manual
The facts are the same as in Example 1 (See OT18131) except that A’s assessable profits are net of unrelated field expenditure of 100 and C ’s assessable profits are net of unrelated field expenditure of 120.
| Participator | Assessable profit | Relievable profit | Unrelated field expenditure |
|---|---|---|---|
| C | 500 | 500 | 120 |
| B | 500 | Nil | - |
| A | 1000 | 500 | 100 |
Participator C: the whole of the interest held by C is comprised in D’s interest so all of C’ s assessable profits are attributable to its represented interest as is the 120 unrelated field expenditure.
Participator B: none of B’s interest is comprised in D’s interest so none of B’s assessable profits are attributable to a represented interest.
Participator A: 50% of the interest held by A is comprised in D’s interest so 50% of A’ s assessable profits are attributable to its represented interest as is 50% of the unrelated field expenditure.
D’s UFL is 30: excess of loss remaining after relieving A and C profits, 200 over aggregate unrelated field expenditure 170 (A + C, 50 + 120).