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HMRC internal manual

Oil Taxation Manual

Capital Allowances: Research and Development Allowances: Geographical Scope of Research and Development Allowances

The decision which gave rise to the RDA practice discussed in this section (& previously SRA) was concerned with exploration onshore in the UK. The 1967 joint memorandum was agreed in the context of exploration in the North Sea.

HMRC accept that exploration outside the UK can qualify for RDA where there is not a well developed understanding of the geology concerned.