.png)
.png)
C Dunne (TC6979)
The taxpayer a non-UK resident was a diver who worked on oil fields in the North Atlantic Ocean. Although the oil fields were outside the UK’s territorial waters it had exploitation rights under the 1958 UN Convention on the Continental Shelf. The oil fields used a vessel for floating production. A rotating turret in the vessel was anchored to the seabed. In 2011 it was decided to decommission the vessel and to help with this the taxpayer carried out dives within the turret.
HMRC said the taxpayer’s earnings from this work was in connection with exploration or exploitation activities (ITEPA 2003 s 41).
The taxpayer appealed saying the exploitation had ended and decommissioning was a separate activity.
The First-tier Tribunal agreed that decommissioning had different purposes from exploitation and could require different skills. However there was a connection between them and this was provided by...
Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.
Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.
