Revenue Note for Guidance
(1) Where petroleum activities are carried on in the course of a trade in conjunction with other activities, the petroleum activities will be treated as a separate trade for tax purposes. This ensures that, for the purposes of the ring-fence provisions relating to petroleum trades, the part of a mixed trade that consists of petroleum activities will be treated as a separate trade.
(2) Where a person works a mine in the State for scheduled minerals that activity will be treated as a separate trade. This provision is necessary because charges on income, losses and group relief arising from such activity may be set off against income from petroleum activities and petroleum profits as an exception to the ring-fence set up around such income and profits by sections 687, 688 and 689.
Relevant Date: Finance Act 2019