Legal Guidance and Research / Experts / Phil Greatrex
Phil Greatrex#1826
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Phil Greatrex

CW Energy LLP

Phil is a partner and founding member of CW Energy in 1990. He is well known in the oil and gas industry as one of the leading tax advisers in this field.

He qualified as a Chartered Accountant with Arthur Young (now part of EY) in London after obtaining a mathematics degree from Southampton University. After four years auditing a wide spread of industrial, service/leisure industry, and financial sector clients, he spent two years advising on accounting and UK company law issues, before transferring to specialise in corporate tax in 1982.

Since then, Phil has been providing tax advice to a wide range of clients, but mainly in the oil and gas sector, on varied, and often complex, issues from cross-border corporate re-organisations, acquisitions and disposals and litigation. He has spent time on secondments with major oil companies and advised the Government of Nova Scotia on the introduction of their offshore royalty regime.

Phil is a regular contributor of articles on various tax issues and has lectured extensively both within the profession and on outside courses. He is the author of a number of publications including, the direct taxation section of Daintith and Willoughby's United Kingdom Oil and Gas Law (published by Sweet & Maxwell), the oil taxation sections of the annual Finance Act Handbook (published by LexisNexis), the oil tax notes in LexisNexis PSL, and the tax sections of Oil and Gas Trading Manuals (published by Woodhead Publishing Ltd). He is also consulting editor for the Oil and Gas Tax section of Halsbury's Laws of England (published by LexisNexis).

As well as corporate and international tax, Phil has a great deal of knowledge and experience in the field of petroleum revenue tax, (PRT) and Government royalties which have now been abolished. He has been a member and secretary of the BRINDEX tax committee since the late 1980's, and has also been an active member of the UKOITC industry tax committee for many years. He was a member of the industry team that produced the Platform for Change document jointly with HMRC and Treasury on the alternative use of North Sea infrastructure for gas store, carbon sequestration etc. In these capacities he has extensive experience of dealing with Treasury and HMRC personnel through the regular industry forum meetings and lobbying for tax changes.

Practice Area

Panel

  • Contributing Author

2 Contributions by Phil Greatrex

UK petroleum revenue tax: computation, reliefs and allowances, zero-rate regime post-2016, opt-outs, tariff receipts, decommissioning, loss carry-back and refunds, and filing/payment rules
PRACTICE NOTES
UK petroleum revenue tax: computation, reliefs and allowances, zero-rate regime post-2016, opt-outs, tariff receipts, decommissioning, loss carry-back and refunds, and filing/payment rules
This Practice Note explains the petroleum revenue tax (PRT) framework. Historically, oil companies were liable to PRT on the value of oil and gas extracted and on receipts for using qualifying infrastructure, after deducting specified costs and reliefs. PRT was charged at varying rates following its introduction in 1975. It stood at 50% from July 1993, then was reduced to 0% with effect from 1 January 2016. Despite the nil rate, losses can still be generated and carried back to recover PRT previously paid. For guidance on the corporation tax, supplementary charge and energy profits levy rules applying to companies in the oil and gas sector, see Practice Note: Oil and gas—corporation tax, supplementary charge and energy profits levy. PRT post 1 January 2016 Under a 0% regime, losses computed under the PRT rules, whether arising on decommissioning or otherwise, must be carried back on a last-in, first-out basis, in accordance with that ordering. They must first be set against profits bearing the 0% rate. Only any excess is then relieved against earlier years, thereby generating actual PRT refunds...
Tax
UK upstream oil and gas tax regime: ring fence corporation tax, supplementary charge, energy profits levy and forthcoming OGPM; PRT, allowances, decommissioning, decommissioning relief deeds, transferable tax history, non-residents
PRACTICE NOTES
UK upstream oil and gas tax regime: ring fence corporation tax, supplementary charge, energy profits levy and forthcoming OGPM; PRT, allowances, decommissioning, decommissioning relief deeds, transferable tax history, non-residents
FORTHCOMING CHANGES : At Budget 2025, the government confirmed that, when the energy profits levy ends, it will be succeeded by a permanent regime known as the oil and gas profits mechanism (OGPM). The principal elements of the OGPM will be as follows: it will constitute a turnover-based tax applying to upstream oil and gas companies operating in the UK or on the UK continental shelf a company will be within scope where it disposes of oil or gas and the consideration received (ie the realised sale price) for that disposal exceeds the relevant threshold. For the financial year 2026–27, the thresholds will be US$90 per barrel for oil and 90p per therm for gas. In subsequent years, those thresholds will be adjusted by reference to the preceding year’s CPI the OGPM tax rate will be 35% The government has stated it will continue to work with the sector to deliver the OGPM as effectively and efficiently as possible. Legislation will be brought forward in Finance Bill 2026–27 to establish the OGPM once the energy profits levy has concluded...
Tax
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