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HMRC internal manual

VAT Land and Property

Supply: place of supply and liability of exploration and production licences in the UK oil industry: VAT liability of oil licences supplied in the UK

Any grant or assignment of a licence relating to land within the UK or its territorial waters is taxable unless the agreement has all the characteristics of a ‘leasing or letting of immovable property’ (see VATLP05700) or is a ‘right over land’ (see paragraph 2.4, Notice 742), in which case it is exempt (unless there is an option to tax).