Taxation of Chargeable Gains Act 1992 section 201

Royalties

Section 201 previously provided relief for mineral royalties by allowing half to be taxed as a chargeable gain, but this relief was repealed from April 2013.

  • Mineral royalties were normally taxable as income under income tax or corporation tax
  • The former relief allowed 50% of eligible mineral royalties to be treated as a chargeable gain, taxed at the generally lower capital gains rates, with the remaining 50% taxed as income
  • Finance Act 2012 repealed this relief from 6 April 2013 for capital gains tax purposes and from 1 April 2013 for corporation tax purposes
  • Since repeal, all mineral royalties are fully taxable as income, whether arising under existing or new agreements and leases

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