OT05424 - PRT: valuation of non-arm's length disposals and appropriations - gas - valuation of light gases from 1 January 1994 - none specific field contracts
»Ê¹ÚÌåÓýappre is no reason in principle why an inter-affiliate contract covering an unspecified source of gas should not be accepted for tax purposes if its terms and prices satisfied the arm’s length principles. »Ê¹ÚÌåÓýappre may however be difficulties identifying the source of the gas used to satisfy the contract and this needs to be examined. »Ê¹ÚÌåÓýapp proposed allocation to the originating fields of the gas sold needs to be carefully checked.