Before April 2013, special rules applied to treat a mineral royalty for tax purposes as containing an 'income element' and a 'capital element', each consisting of a half of the royalty. The income element was treated as property income or trading profits and the capital element was treated as a chargeable gain without any reduction1. Following the repeal of those rules, the whole of a mineral royalty is treated as income liable to income tax or corporation tax. See B5.651.
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