Corporation Tax Act 2010 section 332DC

Restriction relating to fields qualifying for onshore allowance

Section 332DC prevents certain investment expenditure connected with onshore oil fields from qualifying for investment allowance relief, where that expenditure already qualifies for the separate onshore allowance regime.

• Investment expenditure incurred for onshore oil-related activities in respect of an oil field that is a qualifying site for onshore allowance purposes cannot also count as relievable expenditure for investment allowance purposes.
• This restriction applies only where the expenditure is incurred on a day when neither of the disqualifying conditions for onshore allowance eligibility is met — in other words, the field genuinely qualifies for the onshore allowance regime.
• The effect is to prevent a double benefit: expenditure that is eligible under the onshore allowance rules is excluded from the investment allowance rules.
• The definition of "onshore oil-related activities" for this purpose is the same as the definition used throughout the onshore allowance provisions in Chapter 8 of Part 8 of the Act.