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

Published by a LexisNexis Tax expert

Practice notes

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...

To view the latest version of this document and thousands of others like it, sign-in with LexisNexis or register for a free trial.

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...

Web page updated on 22/05/2026

Popular documents

Using the Judicial College Guidelines to assess general damages in personal injury claims

When evaluating a general damages claim, the practitioner ought initially to refer to the Judicial College Guidelines (JCG)...

Tomlin orders in England and Wales: CPR guidance on drafting, confidentiality, approval, variation, enforcement, limitation, CCA issues, court-specific requirements, sample wording and precedents

This Practice Note This Practice Note reviews mechanisms used in settling litigation. A Tomlin order consists of a consent order paired with a schedule. It operates to stay proceedings on terms that have been agreed. The provisions contained in the schedule may remain confidential. This Practice Note describes the scope of confidentiality attaching to the schedule and sets out how it differs from a standard consent order. Sample wording for a Tomlin order is included, alongside links to precedents, as well as guidance on court approval. It also addresses varying, setting aside and enforcing a Tomlin order, including the considerations the court will take into account when handling applications for each. Further guidance is provided on interpreting and applying the relevant provisions of the CPR; however, some courts and divisions impose very specific requirements for both drafting and approval, and for approaching the schedule and confidentiality issues. Accordingly, you must consider the particular rules and court guide provisions in the forum where your claim is proceeding when drawing up the Tomlin order...

Precedent: Deed of Surrender of Lease with Optional Premium, Settlement and Release, Landlord, Mortgagee and Guarantor Consents, Reimbursement and HM Land Registry Provisions (England and Wales)

Date [ date ] Parties [ name of Landlord ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Landlord) [ name of Tenant ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Tenant) [ [ name of Guarantor ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Guarantor) ] [ [ name of Mortgagee ] [ of OR incorporated in England and Wales (company registration number [ number ]) with its registered office at ] [ address ] (Mortgagee) ] Definitions Within this Deed, the terms below shall be interpreted as follows: [ Annual Rent • the annual sum reserved under the Lease; ] [ Insurance Rent • the Tenant’s share of the Landlord’s costs of insuring the Property (as set out in the Lease); ] Lease • the lease of the Property dated [ date ], entered into between (1) [ the Landlord OR [ name ...

Precedent Statutory Declaration: Standard Wording under the Statutory Declarations Act 1835

I, [ name ], of [ address ], solemnly and sincerely state that: [ Matters to be verified, set out in numbered paragraphs ] I make this solemn statement in good conscience, believing it to be true, and pursuant to the provisions of the Statutory Declarations Act 1835. DECLARED at [ details ] this [ day ] day of [ month and year ] Before me ................................................................................ [ signature of the person before whom the declaration is made ] A [ commissioner for oaths OR [ solicitor OR [ insert other qualification ] ] authorised to administer oaths ]...