Other cases that caught our eye: 28 July 2023

Petroleum revenue tax (PRT) and subsidiary argument

In HMRC v Perenco UK Ltd [2023] UKUT 169 (TCC) (19 July 2023) the UT dismissed HMRC's appeal against the FTT decision. Consequently expenditure incurred by the taxpayer during the relevant period to carry out work on its gas terminal to comply with new environmental regulations was allowable expenditure in the computation of its assessable profit for PRT even though part of the cost had been reimbursed by the owners of the oil fields. This was because the UT upheld the FTT's finding that such reimbursement didn't 'meet directly or indirectly' the taxpayer's expenditure on the works being instead additional contractual consideration for the services provided to the oil field owners by the taxpayer. According to the UT 'if A pays a sum of money to B in order to receive goods or services in return on the basis...