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HMRC internal manual

Oil Taxation Manual

Capital Gains: Drilling Expenditure - Part Disposal of Licence


TCGA92\S195(7) provides that on a part disposal of a licence, any expenditure qualifying for a deduction under S195 is attributed wholly to the part disposed of. It is not apportioned under the normal rules at TCGA92\S42 between the part disposed of and the part retained.