BP Oil Development Ltd v Inland Revenue Commissioners

The House of Lords considered the interpretation of the allowance for tariff receipts under the Oil Taxation Act 1983. The key question was whether tariff receipts arising from providing the use of a pipeline and other facilities to another oil field should be aggregated by reference to the totality of receipts from a user field or treated separately for each amount paid for the use of distinct qualifying assets.

The statutory provisions identified for interpretation included sections 6 to 9 of the Oil Taxation Act 1983 and Schedule 3, paragraphs 1(2) and 2(1). The case concerned the scope of the tariff receipts allowance and its calculation in relation to qualifying assets such as pipelines.

Further factual detail and the court's dispositive conclusion are not stated in the judgment.

Background and parties:

• Claimant: BP Oil Development Ltd.
• Defendant: Inland Revenue Commissioners.
• Subject matter: petroleum revenue tax treatment of tariff receipts from providing use of a pipeline and other facilities to another oil field.

Nature of the claim: Not stated in the judgment.

Procedural posture: This is a decision of the House of Lords. Prior stages and detailed appellate history are not stated in the judgment.

Issues framed by the court:

• Whether the tariff receipts allowance is to be calculated by reference to the totality of receipts from a user field or by reference to each separate amount paid for the use of separate qualifying assets.
• How the provisions of the Oil Taxation Act 1983 (notably ss. 6-9 and Schedule 3 paras. 1(2), 2(1)) apply to receipts from pipeline and facility use.

Reasoning and outcome: The judgment identifies the relevant statutory provisions but does not set out the court's detailed reasoning or the operative outcome in the text supplied.

Wider context: The case raises issues about the construction of petroleum revenue tax provisions and the correct basis for allowance calculations where one asset (a pipeline) is used by another field; the supplied text does not contain any extended commentary on policy or precedent impact.