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The taxpayers claimed the foreign earnings deduction for seafarers for 2001/02 2002/03 2003/04 and 2004/05 when they worked outside of the UK on three vessels used for oil production. These vessels were semi-submersible platforms used in the oil exploration business.
Before the hearing it was agreed that for part of the period of the claims the vessels on which the taxpayers were working could not be defined as a ‘ship’ as they fell within the definition of ‘offshore installation’. ITEPA 2003 s 385 states that ‘“ship” does not include an offshore installation’ this latter term being defined in TA 1988 s 837C.
Before ITEPA 2003 an ‘offshore installation’ was as defined in the Offshore Installation and Pipeline Works (Management and Administration) Regulations SI 1995...
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