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OTA75\Sch3\Para11

This is anti-avoidance legislation designed to prevent participators reducing their PRT liabilities by deferring expenditure claims and thereby accelerating their use of oil allowance. Where Schedule 5 and 6 claims are delayed by more than more twelve months after the end of the claim period, oil allowance can be withdrawn under a Board’s direction.

If the deferred claim relates to a period which coincides with a safeguard period, a direction will not be made, though the expenditure may be disallowed under OTA75\S9A, see OT17750.

»Ê¹ÚÌåÓýapp acceleration of oil allowance (outside of safeguard) may also be counteracted by the deferral of assessments. This follows Amoco (UK) Exploration Co v CIR (57TC147, see OT04630).