OT21031 - Corporation Tax Ring Fence and Supplementary Charge

Income from Oil Rights

The acquisition enjoyment or exploitation of oil rights as part of a trade is specifically put within the ring fence by ICTA 1988 S492(1).

However, while income from the acquisition, enjoyment or exploitation of oil rights may be trading income it can also arise outside of a trade.

Thus not all income from oil rights is necessarily trading income. Whether or not is a question of fact to be decided after careful consideration of the particular surrounding circumstances.