TTM03645 - Qualifying companies and ships: Offshore installations
Definition
An 鈥榦ffshore installation鈥� is defined in CTA10/S1132 as:
- a structure which is, or is to be, or has been, put to a relevant use听while in water, and
- relevant use includes exploiting mineral resources by means of a well, related exploration, storage of gas in or under the shore or bed of any waters, recovery of such gas, pipelines and accommodation for workers offshore.
This definition will include such structures as mobile offshore drilling rigs, Floating Production, Storage and Offloading vessels (FPSO鈥檚) and flotels.听 In detail:
Section 1132 Corporation Tax Act 2010
1132 鈥淥ffshore installation鈥�
(1)听听听听 In the Corporation Tax Acts 鈥渙ffshore installation鈥� means a structure which is,听is to be, or has been, put to a relevant use while in water听(see subsections (3) and (4)).
(2)听听听听 But a structure is not an offshore installation if鈥�
听听听听 (a)听听听听 it has permanently ceased to be put to a relevant use,
听听听听 (b)听听听听 it is not, and is not to be, put to any other relevant use, and听听
听听听听 (c)听听听听 since permanently ceasing to be put to a relevant use, it has been put to a use which is not relevant.
(3)听听听听 A use is a relevant use if it is鈥�
听听听听 (a)听听听听 for the purposes of exploiting mineral resources by means of a well,听听
听听听听 (b)听听听 for the purposes of exploration with a view to exploiting mineral听resources by means of a well,
听听听听 (c)听听听听 for the storage of gas in or under the shore or the bed of any waters,
听听听听 (d)听听听听 for the recovery of gas so stored,
听听听听 (e)听听听听 for the conveyance of things by means of a pipe, or
听听听听 (f)听听听听听mainly for the provision of accommodation for individuals who work on听or from a structure which is, is to be, or has been, put to any听of the听above uses while in water.
(4)听听听听 For the purposes of this section references to a structure being put to a use听while in water are to the structure being put to a use while鈥�
听听听听 (a)听听听听 standing in any waters,
听听听听 (b)听听听听 stationed (by whatever means) in any waters, or
听听听听 (c)听听听听 standing on the foreshore or other land intermittently covered with听water.
听听听听 (5)听听听听 In this section 鈥渟tructure鈥� includes a ship or other vessel.
References
FA00/SCH22/PARA20 (1)(d)听(offshore installation) |
|
Excluded vessels |
|
Need to consider end-user of chartered ship |
听