OT63010 - Transferable tax history - Effect of a TTH election on the buyer - Introduction

Where a seller and a purchaser have made a TTH election, and that election has been approved by HMRC, the purchaser may, in certain circumstances, be able to set losses made in its ring fence trade against profits transferred from the seller to the purchaser under the TTH election (“transferred profits”).

In order to be able to set losses against transferred profits, certain conditions must be met:

• the winning of oil from the TTH oil field must have permanently ceased (see OT63020)
• the loss must be a ‘decommissioning loss’ (see OT63030)
• the transferred profits must have been ‘activated’ (see OT64000)