The Court of Appeal has decided, in Total, that companies which would be disadvantaged by a time based apportionment of oil related profits for the purposes of the supplementary charge could elect for a different profit apportionment method, even if their profits were uneven only because of common (rather than exceptional) industry factors. The court also applied a more flexible approach to assessing alternative methods than the Upper Tribunal had. The decision may be relevant to other apportionment provisions.
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The Court of Appeal has decided, in Total, that companies which would be disadvantaged by a time based apportionment of oil related profits for the purposes of the supplementary charge could elect for a different profit apportionment method, even if their profits were uneven only because of common (rather than exceptional) industry factors. The court also applied a more flexible approach to assessing alternative methods than the Upper Tribunal had. The decision may be relevant to other apportionment provisions.
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
.jpg?sfvrsn=335a554c_0 "300 x 250 (MPU)")