Taxes Consolidation Act 1997 section 675

Exploration expenditure incurred by certain bodies corporate

Section 675 allows exploration expenditure incurred by a company within a group to be attributed to any other member of the same group for the purpose of claiming mining tax allowances.

• An exploration company may elect to transfer its qualifying exploration expenditure to a wholly-owned subsidiary, to its parent company, or to another wholly-owned subsidiary of the parent
• The same expenditure may only be relieved against one trade and, apart from transitional provisions, cannot qualify for both an exploration allowance and any other tax allowance
• A company is a wholly-owned subsidiary if all its ordinary share capital is owned directly or indirectly by another company, with any shares held by a government minister disregarded
• The ownership rules in section 9 apply to determine the amount of ordinary share capital held through intermediate companies