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HMRC internal manual

Business Income Manual

HM Revenue & Customs
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Measuring the profits (particular trades): Mineral extraction: commencement of trade

S57 Income Tax (Trading and Other Income)Act 2005, S61 Corporation Tax Act 2009

A trade does not commence until the trader is in a position to provide the relevant goods or services and offers to do so, i.e. has an open door for business (see BIM80500 onwards). Accordingly, the rules as to pre-trading expenses apply to any expenditure before that time.

The date on which a colliery or a mine commences its trade is normally the date on which minerals are first produced for sale, but is a question of fact to be determined in each particular case.

See OT20250 concerning the date of commencement of operations on the Continental Shelf.