Corporation Tax Act 2009 section 135

Relief in respect of mineral royalties

Section 135 provides a relief that halves the taxable amount of mineral royalties when they are included in a company's trade receipts.

• Where a company's trade receipts include mineral royalties, only half of those royalties are brought into account as taxable trade income.
• Most mineral royalties (such as rents from mines and quarries) are taxed as property income rather than trading income, so this relief applies only in limited circumstances.
• The relief is most likely to be relevant where mineral royalties are received by a property developer in respect of land held as trading stock, making the royalties incidental to the trade.
• Although the relief is principally aimed at dealers in land, it is not restricted to them and can apply to any trade where mineral royalties form part of the trade receipts.