Record

CollectionGB 0231 University of Aberdeen, Special Collections
LevelFile
Ref NoMS 3769/1/165
TitleInterview with Christine Mary Kathleen Wheeler (1945-), taxation specialist
Date2002
Extent4 tapes
Administrative HistoryRecorded as part of the 'Lives in the Oil Industry' oral history project
DescriptionTape 1 Side A: CHRISTINE MARY KATHLEEN WHEELER born 25 March 1945 Forest Gate, East London. Paternal family names. Maternal family, Lawler. Paternal grandfather a seaman, worked in Bacton gasworks, night-security man in London docks. Grandmother typical matriarch. Taught to look after men. Influence of grandmother, her positive attitude to women working. Loving family. Recalls brother's marriage into middle class family. Mother's influence on own education, career path. Recalls expectations of women. Grandmother a suffragette. Details. Has half-sister, brother. Details. Mother's attitudes. Father, a crane driver, worked in steelyard, East London, met mother there. Attitude of females in family to 'men's work'. Father one of 22 from four marriages. Grew up aware of social classes. Compares own homelife with others'. Brought up royalist but with idea that Royal Family there to serve people. Impact of Royal Family staying in London during war. Mother Catholic, father protestant. Went to Anglican church. Wanted to be a nun. Enjoyed school, was an achiever at Grammar School. Encouraged to express opinions at home. Was a debater, against trade unions, strongly religious. Explains support of Conservative Party, attitude to class, Britain. Feeling re effects of strikes on London docks. Local attitudes to unions. Influence of history teacher. Encourages daughter to talk - family tradition. Explains own approach to television and children. Unable to go to university. Left school at 16. Joined Inland Revenue c1963. Details. Recalls father's conversation, attitudes to argument. Started work in PAYE office in Stratford, East London. Details. Had 7 GCSE O-levels in arts subjects. Took A-levels in college while working. Describes first job as trainee tax officer dealing with tax coding.

Tape 1 Side B: As teenager, was into pop music, art, reading. Details. Comments on Enid Blyton books. Work in Inland Revenue involved interviewing taxpayers coming into office. Details. First experience of dealing with difficult personal situations. Gives examples. Explains extent of training. Recalls one taxpayer who brought flowers to staff. Recalls lessons learnt about people's behaviour. Importance of sense of humour, work ethic. Own views re tax. Explains significance of different backgrounds of members of ethnic minorities. Promoted twice, to Tax Officer, Inspector Trainee - youngest in country, first female from ranks, rather than from university. Explains role of inspector. Attitude to work. Married at 19. Details re husband, his work later as auditor, running a business. Little social life outside family, friends. Background to joining Arthur Young, Chartered Accountants, 1973. Details re an unfair examination in Inland Revenue, own objection to process, resignation from IR. Feelings about stand taken now. Mentions availability of jobs in 1960s. Family atmosphere in Arthur Young, a happy place. Recalls colleagues in tax practice. Explains tax skills, importance of openness, imagination. First duties involved corporation tax. Details. Handled correspondence for IR. Not conscious of North Sea oil/gas industry then. First contact with offshore sector was through Mobil North Sea tax returns, computations. Details. Reference to Beryl Field. Became directly involved with Mobil. Reference to 1974 Oil Taxation Bill - major shift in tax system. Impression of Mobil personnel. Recalls learning how to unravel any business situation. Comments on small number of women at high levels in business. Some did tax work.

Tape 2 Side A: No difference in treatment of women in civil service. Compares with outside. Own situation. Valuable differences in approach to work of men, women. Explains value of intuition, imagination. Gives example involving an engineering company. Recalls men-only lunches. Value of being only female in meetings. Impact of Finance Act 1973 on areas outside UK and territorial sea, UK Continental Shelf. Reference to double-taxation treaty network. Explains tax collection mechanism involving oil field license operators. Mentions foreign owners of shares in unquoted companies. Type of taxes extended. Unique legislation on taxes - proposed by Conservatives, enacted by Labour Government. Background to 1974 Act. Petroleum Revenue Tax (PRT), different from any other taxes. Got involved in making representations on Bill. Explains key issues, definitions related to PRT. Explains unique character of North Sea field, equipment, technology. Made point of understanding technology, attended technical seminars, helped by oil companies. Better equipped to talk to oil people, Government. Some professionals never understand industry. Mentions industry terminology, e.g. 'farm-ins', complexities of legal relationships between licensees, percentages leading to tax effect. Mentions trans-median fields. Attitude of UK to foreign ownerships. Mobil's attitude to tax. Mentions US tax system, recent Exxon case re PRT, US:UK treaty. Relationships with US companies. No culture clash with Mobil. Explains concept, importance of 'prior clearances'. Only two men ran new legislation proposals - Oswald Davis, David Underdown. Reference to Oil Taxation Office. PRT only tax out of hands of normal Inspectors of Taxes. Explains. Mentions brevity of PRT law. Early years spent making PRT work. Explains overall intent of legislation. Example of possible distortions in tax. Reference to supplements.

Tape 2 Side B: Asked to give advice re 4th Licensing Round. Strong drive in early rounds re British content. Explains effect on Americans, their need for British partners. Recalls Mobil situation. Mentions push for British content. Reference to OSO (Offshore Supplies Office). Recalls pressure from Government, industry to get oil flowing. Mobil largest client of Arthur Young. Also acted for Amerada Hess, other American companies. Initiated formation of specialised oil group in Arthur Young. Result was more business. Compares Mobil, Amerada Hess. Recalls Leon Hess. Story re his desire to make Amerada Hess British in the UK, a memorable meeting in New York. Gives example of his astuteness during Israeli war. Recalls age of entrepreneurs. Business world has changed, doesn't like kind of people who built North Sea. Gives examples. Attitude of current analysts who don't know how to value oil companies. Reference to Tricentral. BNOC (British National Oil Corporation) years difficult for oil industry. Mentions left-wing government. Details re 51% of new licenses taken by BNOC. Like living in third-world state. Oil industry very honourable, blackmailed. Relationship between companies and Tony Benn. Own attitude. Reference to Lord Kirton. Controlling attitude of Government to oil companies. Reference to Edmund Dell's perception of oil companies' power. Lack of female heads of UK companies, two female chief executives of US independents in UK. Details. Uncomfortable period under Benn. BNOC a backdoor process. Recalls arrogance of BNOC personnel. Gives example. Oil industry does not seek limelight. Explains. Had few links with Aberdeen. Comments on fourth licensing round. Impact of father's death. Mother came to look after daughter. Own working hours long.

Tape 3 Side A: Became Partner in Arthur Young. Mobil always big client. Looked after UK independent companies, leader of Oil Group. Explains approach, involvement in entertainment functions. Given no brief by firm. Got involved in network of oil people - created lot of work. Reference to Tricentral, Clyde. Describes process of acquisition, risk sharing arrangements, tax structuring, financial arrangements. Reference to Wytch Farm, enforced sale by British Gas. Acted for 6 independent companies. Reference to possibility of Labour government (early 1980s). Further details re Wytch Farm reservoir, British Gas discovery of large reservoir, their reaction to requirement to sell, difficulty with valuation, need to create royalty. Situation when British Gas privatised. Oil industry personality-based. Explains personal attachments to projects, sense of ownership. Comments on original Petroleum Revenue Tax, changes made, Supplementary Petroleum Duty (SPD), reaction of industry. North Sea was profitable, companies continued to invest. Reference to Advance Petroleum Revenue Tax. Abolition of SPD 1982 through lobbying. Explains own role. Reference to Inland Revenue Oil Policy Division. Explains invitations to IR people to social functions. Explains decision-making process, establishment of trust. Reference to award of OBE. Need for balance between state interests and oil industry. Reference to phasing out Advanced PRT. Mentions Oil Taxation Act 1983, tariffing provisions, link with capital costs. Not much consideration re decommissioning costs in 1980s. Details re 1987 Nominations Scheme, amounts of revenue going from industry to Government, tax charges, traders' 'spinning' processes. Reference to Norwegian situation. Situation today avoiding manipulation of prices set by traders. Comments on level of oil expertise in Inland Revenue, difficulties for industry because of civil service career-path patterns.

Tape 3 Side B: Significance of own role in Government interface with industry. Mentions various interface committees. Details re taxes Act 1988, ring-fencing. Comments on recruitment for Oil and Gas Group. Explains problems with potential recruits coming with university training. Problems with audit training. Recruited 18-year-olds to teach them tax, then took university-trained people into tax department. Gives example of advantage of bottom-up v top-down recruitment, training. Comments on licensing rounds. Mentions contacts with DTI (Department of Trade and Industry), John Brooks. Recalls law suit over trading practices - settled out of court. Details re case, effect of share prices on oil prices, situations getting out of hand. Oil industry eternally pessimistic re oil price. Explains. Comments on public image of oil sector, environmental reputation. Not aware of health and safety issues in early days of industry. Details re letter written to Thompsons after Piper Alpha disaster re payments to victims' families etc. Explains Thompson's appreciation of letter. Details re change in law, at request of Occidental, re instalments of PRT when no production, as in Piper situation. Attitude of oil companies to payment of compensation. Explains State's share of payment because of taxes taken. Comments on Brent Spar issue, cost to State. Own view of Occidental's situation. Piper Alpha disaster created new tax scenario. Explains. Mentions impact of exploration and appraisal tax relief. Comments on change in law to do away with this and stop applying PRT to new fields. Effect of 1993 law. Piper Field still had long life in it. Comments on departure of Occidental and other companies from North Sea. Reference to Intrepid Energy's Buzzard discovery.

Tape 4 Side A: Recalls Armand Hammer at a conference, his long irrelevant speech. Memories of Piper Alpha disaster. Feelings re merger of Ernst & Whinney, and Arthur Young. After merger, appointed Head of Natural Resources Division. Unhappy with situation. Explains. Background to setting up CW Energy Tax Consultants 1990. Situation re restrictive covenants. Clients followed to new consultancy. All staff came. Attitude of Ernst & Young. Recalls day when whole energy unit left Ernst & Young together. Didn't realise a deep recession was on the way. Explains survival through this. Mentions break in all contacts with Inland Revenue and with Ernst & Young after leaving each of them. Benefit of knowledge of workings of IR. Details re husband, his interests, voluntary work etc. Impact of job on family, travel for daughter etc. Impact of Scotland on Government policy because of Scottish vote. Recalls considering possible outcomes if North Sea divided between Scotland, England with independent Scotland. Big tax changes in 1993. Start of interest in decommissioning, potential tax situation. Reference to UKOOA (United Kingdom Offshore Operators' Association). Details re research into decommissioning, costs etc in preparation for law. Attitude of big, small companies to decommissioning, tax situation. Mentions Maureen platform decommissioning. Tax situation re changing use of pipelines. On Advisory Board of Intrepid Energy. Helped start company. Details. Mentions Mike Lynch. Explains starting up an oil company, uniqueness of Intrepid.

Tape 4 Side B: Starting up oil company (cont'd). Intrepid started with no assets but prospects, development projects. Details re purchases in Piper, Claymore, Nelson fields. They have 30% of new Buzzard discovery. Awarded OBE in 1994. Details. Recalls garden party at Buckingham Palace. Feelings about Royal Family. Has met Princess Anne, Prince Charles. Impressions of them and the Queen. Reference Spina Bifida Association, Prince's Trust. Details re gifts from industry to Prince Charles, his reaction. Formed Christine Wheeler & Associates 1991 after divergence of views with colleagues re purpose of CW Energy. Mentions right to use of name. Comments on abolition of PRT 1993. Opinion of PRT. Details re changes aimed at getting people to invest in UK. No exploratory wells being drilled this year (2002). Went to see Stephen Doyle, Financial Secretary of Treasury re 1993 changes. Details of conversation re extra complexity of tax system with different types of fields. Impact of high oil price on State revenue. PRT would be difficult to re-introduce. Explains. Effect of new Supplementary Corporation Tax unacceptable. Explains. Comments on Treasury motivation in introducing new regime. Oil industry an easy target. Industry investors won't come back to North Sea - easier, cheaper elsewhere. Gives example. Lobbying people on situation. Comments on Government attitude to long term stability. Explains current contacts in policy areas. Example of present work: $2B deal for PetroCanada. Mentions work on Editorial Board of Energy and Law Taxation Review. Current staff, work, aims. Family situation. Mentions use of oil revenue during Thatcher years to break back of unions. Improvement in working life in London. Thatcher's attitude to oil industry.
AccrualsNone expected.
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