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Contents

Official guidance
Oil Taxation Manual

OT43000 · Non-residents working on the UK continental shelf: transfer pricing

  • OT43001 · Introduction
  • OT43060 · Interaction with double taxation treaties
  • OT43100 · Drilling operating structures
  • OT43110 · What is a rig?
  • OT43130 · Characteristics of a bareboat charter
  • OT43160 · Bareboat charter - rig market
  • OT43170 · Bareboat charter - types of day rates
  • OT43200 · Bareboat charter - day rates
  • OT43280 · Day rates - semi submersible v jack-ups
  • OT43300 · Bareboat charters - transfer pricing challenge
  • OT43320 · Determining the transfer price - approved methods
  • OT43330 · Bareboat charter - comparable uncontrolled price
  • OT43360 · Bareboat charter - resale price method
  • OT43380 · Bareboat charter - cost plus method
  • OT43400 · Bareboat charter - transactional net margin method
  • OT43450 · Bareboat charter - profit split method
  • OT43455 · Advance pricing agreements
  1. Non-residents working on the UK continental shelf: transfer pricing: contents
  2. Non-residents working on the UK continental shelf: transfer pricing: bareboat charter - rig market

OT43160 | Non-residents working on the UK continental shelf: transfer pricing: bareboat charter - rig market

From HM Revenue & Customs · Oil Taxation Manual

Before any conclusions can be drawn on bareboat charter rates it is necessary to understand something of the rig market:

  • There is only a small market for the hire of a drilling rig on bareboat charter terms.

  • Such charters are usually only seen between members of the same group.

  • Tax mitigation may be a primary motive behind such arrangements.

When choosing a rig an oil company will be concerned not only with the rig itself but the group behind it; the rig operator is as important as the rig. Large groups therefore have a competitive advantage because of competent, experienced crews and knowledgeable and efficient administrative backup services and good quality equipment. The high capital cost of rigs is also a factor. As a consequence the market is dominated by a small number of larger companies, although new operators do enter the market periodically.

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