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Consultation released on the future of oil and gas taxation

The consultation considers the mechanism, from 2030, by which oil and gas profits in the UK will operate where there are price shocks

The Government has launched a consultationopens in a new tab on the future of oil and gas taxation in the UK.

The proposed new Oil and Gas Price Mechanism aims to tax oil and gas income arising in the UK where there are price shocks. This new ‘windfall tax’ will replace the Energy Profits Levy (EPL) which was first introduced in 2022 and is due to end in 2030 (or earlier if the Energy Security Investment Mechanism is triggered). The ring fence tax regime which applies corporation tax at a rate of 30 percent and the supplementary charge to corporation tax at 10 percent will remain in place. 

Two policy options are put forward: 

  • A revenue-based model which will tax revenues above a price threshold. It is envisaged that taxable revenues will be after the effect of any hedging, but no costs will be deductible. This tax may apply on a transaction-by-transaction basis which may give rise to a significant administrative burden; or
  • A profit-based model which will tax profits equal to the difference between realised average market prices and a threshold. Profits will be calculated on the same basis as the EPL, with no relief for decommissioning or finance costs.
Claire Angell

Partner, Head of Energy Tax

KPMG in the UK

Under both options separate oil and gas price thresholds may be introduced to recognise the differences between oil and gas prices. This would make the profit-based model more complex to implement, as there will be a requirement to allocate profits between oil and gas related activities. This is not currently required under existing UK oil and gas taxation.

The Government has not indicated where the thresholds will be set but will consider a number of factors through the consultation, including historical and forward-looking price assumptions used in the sector. Pre-determined rules will be included to adjust the thresholds over time, for example applying CPI or GDP based adjustments.

The consultation will close on 28 May 2025.

 

 

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