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Contents

Official guidance
Oil Taxation Manual

OT43000 · Non-residents working on the UK continental shelf: transfer pricing

  • OT43001 · Introduction
  • OT43060 · Interaction with double taxation treaties
  • OT43100 · Drilling operating structures
  • OT43110 · What is a rig?
  • OT43130 · Characteristics of a bareboat charter
  • OT43160 · Bareboat charter - rig market
  • OT43170 · Bareboat charter - types of day rates
  • OT43200 · Bareboat charter - day rates
  • OT43280 · Day rates - semi submersible v jack-ups
  • OT43300 · Bareboat charters - transfer pricing challenge
  • OT43320 · Determining the transfer price - approved methods
  • OT43330 · Bareboat charter - comparable uncontrolled price
  • OT43360 · Bareboat charter - resale price method
  • OT43380 · Bareboat charter - cost plus method
  • OT43400 · Bareboat charter - transactional net margin method
  • OT43450 · Bareboat charter - profit split method
  • OT43455 · Advance pricing agreements
  1. Non-residents working on the UK continental shelf: transfer pricing: contents
  2. Non-residents working on the UK continental shelf: transfer pricing: bareboat charter - resale price method

OT43360 | Non-residents working on the UK continental shelf: transfer pricing: bareboat charter - resale price method

From HM Revenue & Customs · Oil Taxation Manual

This is the second of the methods referred to in OT43320. Paragraphs 2.14 to 2.31 of the OECD Guidelines indicate how the resale price method applies to the sale of goods, and that its use is aimed at marketing type operations. It is not considered that the method translates suitably to drilling operations because significant value is usually added to the lease rents by the provision of drilling services as well as by the rig performance itself.

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