All at sea

Our client who already has a qualifying period for treatment as a seaman with 100% relief from earnings will now be spending some time with the Royal Navy on a ship which will be in international waters.

We do not believe that the income from the engagement will qualify for relief.

However we are wondering whether the days working with the Royal Navy will still count as outside the UK in the same way that holiday would in assessing whether the 50% test has been broken when the client resumes seaman’s duties on a qualifying trip on a qualifying vessel.

Query 18 409 – All at Sea

Reply from SK

All at Sea is quite correct that the income from the Royal Navy engagement will not qualify for the seafarers’ earnings deduction because ITEPA 2003 s 384(1) excludes crown employment from qualifying as employment...