OT69010 - Transferable tax history - Miscellaneous - Capital Gains

The general position is that no value should be assigned to the transfer of tax history for capital gains purposes when a TTH election is made. Value should be split between the value of the licence (i.e. to the right to win the oil from the licensed area) and the value of any infrastructure, plant and machinery acquired as part of the transaction, as is the case currently.

If, exceptionally, any value in a transaction is attributed to the tax history transferred, for CG purposes that value should be attributed to the value assigned to the licence interest transferred.