Part 4 Effect of a TTH Election on the Purchaser

Part 4 Effect of a TTH Election on the Purchaser

Application of this Part

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This Part applies if—

(a)     the seller and the purchaser have jointly made a TTH election in respect of the TTH asset,

(b)     the TTH election has been approved by an officer of Revenue and Customs (see paragraphs 61 and 62),

(c)     the winning of oil from the TTH oil field has permanently ceased, and

(d)     in a post-acquisition accounting period (the “loss period”)—

(i)     the purchaser makes a loss in a ring fence trade,

(ii)     the loss is a decommissioning loss, and

(iii)     the purchaser holds, for the loss period, an activated TTH amount (see Parts 5 and 6).

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In paragraph 23(d)(ii), “decommissioning loss” means a loss in respect of which—

(a)     a claim for relief under section 37 of CTA 2010 is made by the purchaser by virtue of section 39 or 40 of that Act (relief for trade losses: terminal losses and ring fence trades), or

(b)     relief is given under section 42 of CTA 2010 (ring fence trades: further extension of period for relief).

Effect of trade loss relief provisions

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(1)

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