SCHEDULES
SCHEDULE 15Oil activities: transferable tax history
PART 4Effect of a TTH election on the purchaser
Application of this Part
23
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).
24
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).