To qualify for the new treatment in BIM62090, the royalties must be received under an agreement under which minerals are being, or are to be, worked in the UK. The terms ‘mineral royalties’, ‘minerals' and ‘mineral lease or agreement' are defined in ICTA88/S122 (5) and (6). Only payments that relate to the winning and working of minerals qualify. Broadly ‘winning' means getting at the minerals and ‘working' means getting them out of the ground.
