RE1950 - Mineral rights: management expenses: title to and extent of relief


A lessor of rights to work minerals in the United Kingdom may incur expenses of management or supervision of those minerals. He can claim relief for sums he pays out wholly, exclusively and necessarily on such expenses including the cost of collection.

The relief for expenses of management or supervision is limited to the amount of the tax paid by deduction or otherwise in respect of the rent or royalties for that year, less any tax on charges.

The rent or royalties fall within S122 ICTA1988 and only 50% of receipts are taxed as income. The management expenses available for set-off are also reduced by one-half. There are separate instructions about relief in respect of mineral royalties received at BIM62098 onwards.