Corporation Tax Act 2009 section 273

Relief in respect of mineral royalties

Section 273 provides that only half of the net profit from mineral royalties is subject to corporation tax as income, with the other half being taxed as a chargeable gain.

• Only 50% of the net profit from mineral royalties is charged to corporation tax on income.
• The remaining 50% of the net profit is instead charged to corporation tax on chargeable gains.
• This relief applies specifically to mineral royalties taxed under the relevant chapter of the Corporation Tax Act 2009.
• If the royalty is taxed under a different part of the legislation, equivalent relief is available through separate provisions.