OT60010 - Transferable tax history - Introduction

The Transferable Tax History (TTH) mechanism allows companies selling an interest in an oil and gas licence on the UK Continental Shelf (UKCS) to transfer some of their tax payment history to the purchaser of those fields. The purchasers will then be able to set the costs of decommissioning the fields against the TTH. This will level the playing field between purchasers and sellers of oil and gas fields, providing new investors in the UK Continental Shelf with certainty on the tax relief available for the decommissioning costs.

The legislation introducing Transferable Tax History [Link] applies for transfers of licence interests approved by the North Sea Transition Authority (NSTA) on or after 1 November 2018 and this guidance provides an overview and examples of how TTH works.