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HMRC internal manual

Oil Taxation Manual

Capital gains: consideration other than cash: licence swaps - reimbursed expenditure

FA2011 introduced TCGA92\S195F which applies to disposals made on or after 23 March 2011.

This section ensures that costs for chargeable gains purposes in respect of licences disposed of rest with the appropriate company. It provides that where a company incurs expenditure on a licence before a disposal which falls within TCGA92\S38(1)(b), and the expenditure is reimbursed by the company to whom the disposal is made, the expenditure is treated as expenditure incurred by the other company on the licence after the disposal and which falls within TCGA92\S38(1)(b).