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Contents

Official guidance
Oil Taxation Manual

OT26000 · Capital allowances: research and development allowances

  • OT26001 · Introduction
  • OT26002 · Meaning of oil & gas exploration and appraisal
  • OT26005 · Judicial Comment on Scientific Research and Oil Exploration
  • OT26007 · Joint memorandum of 1967
  • OT26008 · 1967 Memorandum - Details
  • OT26009 · 1967 Memorandum - Successive Stages of Work - Stages 1 & 2
  • OT26010 · 1967 Memorandum - Successive Stages of Work - Stages 3, 4 &5
  • OT26013 · Tribunal reform of 01 April 2009
  • OT26015 · HMRC view on the 1967 Memorandum
  • OT26016 · 1967 Memorandum - HMRC view on the Meaning of Field
  • OT26017 · 1967 Memorandum - HMRC view on exclusions
  • OT26018 · 1967 Memorandum - HMRC view on end of Stage 3
  • OT26026 · Using reserve reporting for deciding on the availability of RDAs
  • OT26027 · 1967 memorandum - gaps between stages 3 and 4 in oil exploration and development
  • OT26030 · RDA Claims during production operations
  • OT26035 · Commencement of Trade
  • OT26036 · Geographical Scope of Research and Development Allowances
  • OT26041 · US Oil & Gas Partnerships
  • OT26045 · The purchase of the results of past exploration work
  • OT26050 · Redeterminations and Unitisations
  • OT26052 · Disposal of a licence interest
  • OT26054 · Disposal of a licence for an undeveloped area
  • OT26056 · The allowance of certain drilling expenditure
  • OT26058 · Treatment of Payments for Production Licences
  • OT26060 · Farm-ins
  1. Capital allowances: research and development allowances: contents
  2. Capital Allowances: Research and Development Allowances: Introduction

OT26001 | Capital Allowances: Research and Development Allowances: Introduction

From HM Revenue & Customs · Oil Taxation Manual

The provisions for research and development allowances were introduced in FA2000 and apply for corporation tax to accounting periods ending on or after 1 April 2000.

The capital cost of most oil and gas exploration and appraisal activity is allowed as a deduction under CAA01\S437 as expenditure of a capital nature on research and development (R&D). The rate of Research and Development Allowances (RDA) is 100%.

Research and Development (R&D) is defined at CAA01\S437 and CAA01\S437(2)(b) it expressly includes oil and gas exploration and appraisal (E&A) as being research and development.

Prior to 1 April 2000, relief had been available to companies incurring expenditure on “scientific research” in the course of oil and gas exploration and appraisal work by way of scientific research allowances.

The guidance that follows relates specifically to the availability of Research and Development Allowances (RDA) on oil and gas exploration and appraisal activities. More detailed guidance on RDA can be found in the Capital Allowances manual at CA60100.

Detailed guidance on the Research and Development Tax Credits regime can be found in the Corporate Intangibles and Research & Development Manual at CIRD80000.

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