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HMRC internal manual

Oil Taxation Manual

Capital Allowances: Research and Development Allowances: Redeterminations and Unitisations


HMRC take the view that the liabilities that are settled by a redetermination were always present and thus the redetermination merely quantifies a pre-existing liability. RDA can therefore be claimed by the increasing interest party making a payment in respect of exploration conducted at an earlier date. This research was always incurred on behalf of the increasing interest party


Unitisations are not so clear-cut and an RDA claim will depend on the terms and history of the particular agreement.