Commentary on Sections Overview Overview Section 339: Deduction for management expenses of owner of mineral rights
1386.This section allows a deduction for the expenses of managing mineral rights. It is based on section 121(1) of ICTA.
1387.Subsection (1) sets out the conditions for the section to apply. It does not reproduce the condition that the expenses must be incurred “necessarily”. See Change 78 in Annex 1.
1388.Subsection (2) provides that a deduction is allowed for the qualifying expenses paid in the tax year. This rewrites the requirement that the expenses are “disbursed” in the tax year.
1389.The relief applies only to rents received from a UK section 12(4) concern. If the income is taxed as income from a UK property business, there is no need for special rules identifying what deductions are allowable. The normal rules apply.