Related Commentary  Related HMRC Manuals

408(1)  This section applies if–

(a)a person carrying on a mineral extraction trade (“the buyer” ) incurs capital expenditure on acquiring an interest in an oil licence for the purposes of that trade,

(b)the person from whom the interest was acquired (“the seller” ) disposed of the interest without having carried on a mineral extraction trade,

(c)part of the value of the interest is attributable to expenditure (“E1” ) on mineral exploration and access by the seller, and

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