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HMRC internal manual

Oil Taxation Manual

From
HM Revenue & Customs
Updated
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Capital Gains: Drilling Expenditure - Pre Trading Expenditure

TCGA92\S195(6)

Where, on disposal of a licence, a deduction for drilling expenditure is made under TGCA92\S195 to a company which has not yet commenced trading, TCGA92\S195(6) prevents the expenditure from qualifying for research and development allowance relief on any subsequent trade commencement.