OT19430 - PRT: Appendices

Company Reorganisation

Where the transfer of a field interest is part of a company re-organisation it can happen, as a result of applying the Schedule 17 FA 1980 provisions, that taken together, the two companies pay more PRT than would have been due had the re-organisation not taken place.

It was always recognised that Schedule 17 would not in every case result in exactly the same amount of tax being charged. Indeed, it is quite clear that some of the provisions (e.g. FA80/SCH17/PARA17 re Oil allowance - see OT18150) would inevitably result in a difference in the tax charge.