Corporation Tax Act 2009 section 272

Deduction for management expenses of owner of mineral rights

Section 272 allows a company that lets mineral rights in the United Kingdom to deduct management and supervision expenses from the rent it receives.

• A company that lets a right to work minerals in the UK may claim a deduction for expenses of managing or supervising those minerals.
• The expenses must be paid wholly and exclusively for the purpose of management or supervision of the minerals during the accounting period.
• The deduction is made against the rent receivable from what is classified as a UK section 39(4) concern (broadly, a mine, quarry or similar operation taxed as trading income).
• Where mineral income is instead taxed as UK property business income, the normal property business deduction rules apply and this special provision is not needed.