CATS North Sea Ltd v HMRC

In CATS North Sea Ltd v HMRC [2024] UKFTT 512 (TC) (6 June) the FTT considered the interaction between the corporation tax oil and gas ring fence provisions the transfer of trade without change of ownership provisions at CTA 2010 Part 22 Chapter 1 (the transfer of trade provisions) and capital allowance provisions relating to disposal events at CAA 2001 s 61 in the context of a hive-down of an oil and gas pipeline. 

The taxpayer was the transferee in a hive-down of an interest in a North Sea oil and gas pipeline within the group of companies headed by BP plc. For the transferor in the hive-down the activities in respect of the pipeline were wholly inside the oil and gas ring fence however for the taxpayer only the transport of group hydrocarbons were treated as being inside the oil and gas ring fence whereas...