OT03545 - PRT: Changes - FA93 - Tariffs and tariff-related expenditure
Where both the paying and receiving fields are 바카라 사이트渢axable바카라 사이트�, then both the relief for the tariff- related expenditure and the corresponding tariff income will be within the scope of PRT, and the pre FA93 rules will continue to operate.
On the other hand, where both the tariff-related expenditure and the tariff income relate only to 바카라 사이트渘on-taxable바카라 사이트� fields then they will both be outwith the scope of PRT.
FA93\S193(2)(3) is an anti-avoidance provision which denies an expenditure deduction for tariffs or other payments from a 바카라 사이트渢axable바카라 사이트� field to a 바카라 사이트渘on-taxable바카라 사이트� field where any of the participators in the two fields are 바카라 사이트榗onnected within the meaning of ICTA88\S839. It is aimed at preventing inflated tariff or other payments, e.g. service charges, between connected parties that reduce profits for PRT and is necessary because the corresponding receipt will not itself be chargeable to PRT.
For example a participator who has already built a pipeline will gain no benefit from re-routing it to a 바카라 사이트渘on-taxable바카라 사이트� field in which he or someone associated with him is a participator and arranging for a tariff to be paid to the 바카라 사이트渘on-taxable바카라 사이트� field.
Tariffs - transmedian fields
FA93\S193(4) amends OTA83\S12(3) so that, for a transmedian field, if that part of the field on the UK side of the boundary is a taxable field, then the foreign part of the field shall be treated as if it were a taxable field for tariffing and disposals. If the UK side is non-taxable, then the foreign part will also be treated as non-taxable.