OT26603 - Capital Allowances: Long Life Assets - Expenditure excluded from being on Long Life Assets - Ships and offshore installations

CAA01\S94

CAA01\S94 excludes from LLA鈥檚 expenditure incurred before 1 January 2011 on the provision of a ship of a seagoing kind and the ship is not an offshore installation (see CA23730).

Floating Production Storage and Offloading Vessels (FPSO鈥檚) may appear to be ships but whether or not they are will be dependent on the facts of each case (see CA25100).

However, the CAA01\S94 exclusion from LLA鈥檚 does not apply if the 鈥渟hip鈥 falls within the definition of an 鈥渙ffshore installation鈥 for the purposes of the Mineral Workings (Offshore installations) Act 1971. This Act defines offshore installation as meaning:

  • 鈥渁ny installation which is or has been maintained, or is intended to be established, for the carrying on of any activity to which this Act applies鈥.

As the activities to which the Act applies include:

鈥渢he exploitation or exploration of mineral resources in or under the shore or bed of controlled waters鈥,

and as installation includes:

鈥渁ny floating structure or device maintained on a station by whatever means鈥.

HMRC consider that Floating Production Storage and Offloading Vessels (FPSO鈥檚) fall within the definition of long life assets if their expected working life when new is at least 25 years.