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HMRC internal manual

Capital Allowances Manual

MEA: Group transfers: transfer of mineral assets within a group

Where a mineral asset is transferred between companies under common control:

  • and there is no election under CAA01/S569 - S570,
  • then CAA01/S412 (2) provides that the transferee is treated as incurring qualifying expenditure of no greater amount than the expenditure incurred by the transferor.