408 Acquisition of oil licence from non-traderU.K.
(1)This section applies if—
(a)a person carrying on a mineral extraction trade (“the buyer”) incurs capital expenditure on acquiring an interest in an oil licence for the purposes of that trade,
(b)the person from whom the interest was acquired (“the seller”) disposed of the interest without having carried on a mineral extraction trade,
(c)part of the value of the interest is attributable to expenditure (“E1”) on mineral exploration and access by the seller, and
(d)it is just and reasonable to attribute part of the buyer’s expenditure (“E2”) to that part of the value of the interest.
(2)If this section applies—
(a)so much of the buyer’s expenditure as is equal to the lesser of E1 and E2 is to be treated as qualifying expenditure on mineral exploration and access, and
(b)the buyer’s expenditure on acquiring the interest in the oil licence is reduced by an amount equal to E2.
(3)In this section “oil licence” and “interest in an oil licence” have the same meaning as in Chapter 3 of Part 12.