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DOMINIC CRILLY blasts HMRC’s views on the application of taper relief to mineral royalties
KEY POINTS
- Is taper relief still available to mineral royalties?
- Application of TCGA 1992 s 22.
- Definition of a disposal.
- A real or a deemed disposal?
- Taper relief should be claimed.
Sometimes it is only when the hole has been dug and the dust has settled that we can really see how the land lies. This certainly seems to be true of the application of taper relief to mineral royalties.
The taxation of mineral royalties was covered in Julie Butler’s excellent article Gravel money and I do not intend to dig up old ground. Suffice it to say that ITTOIA 2005 s 340 and TCGA 1992 s 201 act to bring half of all mineral royalties receivable into...
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