SolvedOT30104 | Capital Gains: Drilling Expenditure - Pre Trading Expenditure
From HM Revenue & Customs · Oil Taxation Manual
TCGA92\S195(6)
Where, on disposal of a licence, a deduction for drilling expenditure is made under TGCA92\S195 to a company which has not yet commenced trading, TCGA92\S195(6) prevents the expenditure from qualifying for research and development allowance relief on any subsequent trade commencement.