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Section 195A: Oil licence swaps

Taxation of Chargeable Gains Act 1992 · 1992 c. 12View on legislation.gov.uk

Part VI: Companies, oil, insurance etc. — Chapter II: Oil and mining industries

Sections 195B to 195F apply for the purposes of corporation tax on chargeable gains.

In those sections—

  • "licence-consideration swap" means a case where conditions A, B, C and D are met;

  • "mixed-consideration swap" means a case where conditions A, B, C and E are met.

Condition A is that a company ("company A") disposes of one or more UK licences to another company ("company B"), by way of a bargain at arm's length ("disposal A").

Condition B is that company B disposes of one or more UK licences to company A, by way of a bargain at arm's length ("disposal B").

Condition C is that either or both of the following paragraphs applies—

the licence, or at least one of the licences, comprised in disposal A relates to a developed area;
the licence, or at least one of the licences, comprised in disposal B relates to a developed area.

Condition D is that both—

disposal A is the only consideration given for disposal B, and
disposal B is the only consideration given for disposal A.

Condition E is that either—

disposal A is the only consideration given for disposal B, or
disposal B is the only consideration given for disposal A,

(and accordingly one of the disposals is part of the consideration given for the other disposal).

In this section and sections 195B to 196 a reference to disposal of a UK licence includes—

a disposal of an interest in a UK licence, and
a disposal of a UK licence, or an interest in a UK licence, only so far as the licence relates to part of the licensed area.

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This legislation text comes from legislation.gov.uk. Contains public sector information licensed under the Open Government Licence v3.0. These source and reuse terms cover the legislation text, not Remedy's commentary.

Reuse reviewed 21 August 2026 under Open Government Licence v3.0.