This case related to the apportionment of company profits during a transitional period in which the supplementary tax charge on ring fence oil and gas profits increased from 20% to 32%. The legislation provided for time-based apportionment of taxable profits during the transitional period but companies could, where such basis of apportionment produced an unreasonable result, apportion on a "just and reasonable" basis.

The FTT permitted the taxpayer's use of a just and reasonable apportionment basis. In particular, the taxpayers only had to show that their approach was a just and reasonable approach, not that it was the most just and reasonable approach.

This is of general interest because profits arising in accounting periods straddling the introduction of the interest deduction restriction and new carried forward loss rules, among other similar rules, need to be apportioned for the purposes of those rules on a just and reasonable basis across the periods before and after the new rules come into effect and the decision limits HMRC's ability to second guess a taxpayer's reasonable approach to that apportionment.