Revenue & Customs brief 35/07

Tax Credit Relief

Sharjah – Petroleum Revenue Tax

HMRC has changed its view on the admissibility of the Petroleum Revenue Tax charged in Sharjah on profits arising out of production sharing contracts or petroleum concession agreements entered into between companies and the Emirate of Sharjah.

We now consider this tax to be paid under the law of a territory outside the United Kingdom and computed by reference to income arising in Sharjah. It will therefore qualify for unilateral relief under Section 790 Income and Corporation Taxes Act 1988.

The amount of relief due in a particular case (including any further claims arising from this change of view) should be agreed in the usual way with:

CT & VAT
Underlying Tax Group
Fitz Roy House
PO Box 46
Nottingham NG2 1BD

The Double Taxation Relief guidance manual (DT16751) will be amended shortly to reflect this change of view.

If you have any queries arising from this change please contact:

Kevin Madley
HMRC
Frontiers & International Tax Treaty Team
100 Parliament Street
London
SW1A 2BQ 6ES
Tel: 020 7147 2661
Email: Kevin Madley

Issued 10 April 2007