[The appeal against this decision is reported at [2009] BTC 292.]

Colin Bishopp

Decision released 13 September 2007

Income tax – Mining royalties – ICTA 1988, s. 119, 122, TCGA 1992, s. 201 – Whether ‘mining’ and ‘working’ distinct and cumulative conditions for application of s. 122 – Such interpretation excessively strict – Appeal allowed


Payments receivable by the taxpayer in return for the rights to drill, prospect and explore for coal, to extract coal by open cast mining and to disturb other minerals for the purpose of mining coal, were taxable under the Income and Corporation Taxes Act 1998, s. 122.


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