RE: 'tax synergies'6 Oct 2020 10:49
Mirasol,
I cannot comment on HMRC provisions on O&G, and how sharp they are in that industry. I'm not in the O&G industry myself.
Do you speak from experience? Do you have any examples of scenarios/legal cases where HMRC has taken action against an oiler?
I have a few mates who work for HMRC (they could earn more in the City), they would be insulted to be told that they are not as sharp as colleagues who may focus on O&G. Maybe it is more a case of industry specific experts, rather than having the "top guns" working in one particular industry.
One thing I can tell you, it that it takes forensic accounting and very well run audit to uncover the most significant opportunities that a group may take. e.g. In a situation where output cannot be increased, UKOG as a subsidiary may be able to make a small profit, but if they could reduce costs, then they can increase profit. The art of the game is to have the Group cover some of the costs, but to cover those up through accounting wizardry. Examples:
- Group may use a supplier for haulage, cancel the BKP contact and let UKOG make use of their existing haulage agreement, but charge a much lower rate than a pro rata charge
- Group will have their own payroll and back-office functions. UKOG folk could be made redundant, and then group provide those functions. And guess what, they could charge a figure well below the actual costs. Its a track the wooden dollar exercise.
- UKOG could purchase assets from Group at a reduced rate. e.g. UKOG may benefit from owning further equipment rather than renting it (as was the case with the recent PW Well kit purchase). Group could purchase those assets, deploy them somewhere for a short period, then transfer them onto UKOG at the reduced rate
There's plenty of games and tricks, and as you have already noted, it would take the right people at HMRC with the sharpest skills to spot it all. And even then, it can become very difficult to prove that Group had acted inappropriately.