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Finance Act 2019 introduced a transferable tax history (TTH) mechanism for transfers of UK oil and gas field interests where Oil and Gas Authority (renamed to the North Sea Transition Authority in 2022) consent for the transfer is received on or after 1 November 2018¹. These rules allow companies selling UK North Sea oil and gas fields to jointly elect with the buyer to transfer some of their ring fence corporation tax and supplementary charge history to the buyer of that fields². The buyers will then be able, to the extent they do not have sufficient own tax history (and provided that the transferred tax history is activated as described below), to set the losses derived from the costs of de-commissioning any fields against the TTH. The election must be made jointly and notified to HMRC on a date between the licence transfer date and 90 days after that date (or, if later, 1 June 2019)³. The election must be approved by an officer of HMRC⁴.

The TTH mechanism allows an