{
  "url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005/section-225M",
  "json_url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005/section-225M.json",
  "legislation": "ukpga/2005/5",
  "legislation_title": "Income Tax (Trading and Other Income) Act 2005",
  "legislation_url": "https://openlegislation.uk/income-tax-trading-and-other-income-act-2005",
  "path": "section/225M",
  "kind": "section",
  "number": "225M",
  "heading": "Tariff receipts etc",
  "text": "(1) Subsection (5) applies to a sum which meets conditions A, B and C.\n(2) Condition A is that the sum constitutes a tariff receipt or tax-exempt tariffing receipt of a person who is a participator in an oil field.\n(3) Condition B is that the sum constitutes consideration in the nature of income rather than capital.\n(4) Condition C is that the sum would not, but for subsection (5), be treated as mentioned in that subsection.\n(5) The sum is to be treated as a receipt of the separate trade mentioned in section 16(1) (oil extraction and related activities).\n(6) So far as they would not otherwise be so treated, the activities—\n(a) of a participator in an oil field, or\n(b) of a person connected with the participator,\nin making available an asset in a way which gives rise to tariff receipts or tax-exempt tariffing receipts of the participator are to be treated for the purposes of this Chapter as oil extraction activities.\n(7) In determining for the purposes of subsection (2) whether a sum constitutes a tariff receipt or tax-exempt tariffing receipt of a person who is a participator, no account may be taken of any sum which—\n(a) is in fact received or receivable by a person connected with the participator, and\n(b) constitutes a tariff receipt or tax-exempt tariffing receipt of the participator.\nBut in relation to the person by whom such a sum is actually received, subsection (2) has effect as if the person were a participator and as if condition A were met.\n(8) References in this section to a person connected with a participator include a person with whom the person is associated, within the meaning of paragraph 11 of Schedule 2 to the Oil Taxation Act 1983, but section 878(5) of this Act (application of definition of “connected” persons) does not apply for the purposes of this section.\n(9) In this section—\n“tax-exempt tariffing receipt” has the meaning given by section 6A(2) of the Oil Taxation Act 1983, and\n“tariff receipt” has the same meaning as in that Act.",
  "extent": null,
  "status": null,
  "version": "current",
  "annotations": [
    {
      "type": "F",
      "label": "F1",
      "text": "Pt. 2 Ch. 16A inserted (with effect in accordance with s. 381(1) of the amending Act) by Taxation (International and Other Provisions) Act 2010 (c. 8), s. 381(1), Sch. 1 para. 2 (with Sch. 9 paras. 1-9, 22)"
    }
  ],
  "outstanding_effects": [],
  "provenance": {
    "source": "legislation.gov.uk",
    "source_url": "https://www.legislation.gov.uk/ukpga/2005/5/section/225M",
    "retrieved_at": "2026-10-29T09:16:32.370392+00:00"
  },
  "licence": "Open Government Licence v3.0",
  "licence_url": "https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/",
  "attribution": "Contains public sector information licensed under the Open Government Licence v3.0. Source: legislation.gov.uk, The National Archives."
}