Petroleum Revenue Tax (PRT) – allowable expenditure – taxpayer win

The First-tier Tribunal has allowed an appeal by Perenco UK Limited against a decision by HMRC to disallow expenditure claims made by Perenco in respect of the costs of replacing cooling plant at a gas processing terminal.  HMRC had maintained that the expenditure fell to be disallowed for PRT purposes under Oil Taxation Act 1975 Schedule 3 paragraph 8 on the basis that the expenditure had been “met directly or indirectly” by the owners of three gas fields who paid to use the terminal (and its associated offshore systems) under the terms of various transportation and processing agreements, or TPAs.

The decision of the FTT in Perenco Limited v HMRC v HMRC [2021] UKFTT 0254 (TC) can be found here.

John Brinsmead-Stockham acted for Perenco UK Limited, instructed by CW Energy.