Corporation Tax Act 2010 section 356CB

Expenditure not related to an established site

Section 356CB provides for how a company is to treat capital expenditure on onshore oil-related activities that was incurred before a specific site has been identified.

• A company may elect to allocate capital expenditure on onshore oil-related activities to a specified site, provided that at the time of the election no site can be identified as the site to which the expenditure relates.
• The election cannot be made before the beginning of the company's third accounting period after the one in which the expenditure was originally incurred.
• The election must specify the expenditure, a site (the "specified site") within an area where the company is a licensee, and an accounting period (the "specified accounting period") that is no earlier than the period in which the election is made.
• Once the election is made, the expenditure is treated for the purposes of the onshore allowance rules as having been incurred in relation to the specified site at the beginning of the specified accounting period.