CA50120 - MEA: Scope of Relief: What is a “mineral extraction trade” ?
Allowances are available under CAA01/S394 (1) if a person “carries on a mineral extraction trade and incurs qualifying expenditure”.
A “mineral extraction trade” is defined in CAA01/S394 (2) as a trade that consists of or includes the working of a source of mineral deposits but only to the extent that the profits or gains from the trade are, or would be chargeable to tax.
CAA01/S394 (3) defines “mineral deposits” to include “any natural deposits capable of being lifted or extracted from the earth”, and confirms that “geothermal energy” is to be treated as a natural deposit for this purpose. All references to mineral deposits in the MEA legislation are to mineral deposits of a wasting nature (CAA/S394(4)).
“Source of mineral deposits” includes a mine, an oil well and a geothermal energy source (CAA01/S394 (5)).