TTM03570 | Qualifying companies and ships: Transport by sea in connection with other services of a kind necessarily provided at sea

Definition

As industry practice and the nature of operations at sea develop, it becomes more difficult to address the issue of what is covered by the services at sea definition purely by reference to a list of vessel types. Increasingly vessels are multifunctional, and types of sea-borne operations evolve and develop. When the original vessel list below was devised, offshore windfarm servicing, including repairing and dismantling, was unknown, as were specialist vessels for pollution control. The nature of marine research has developed significantly . A need for guard vessels has developed.

As a result, although the sweeping-up definition of FA00/SCH22/PARA19 (1)(d) covers the activities of a variety of vessel types, it cannot effectively be addressed purely by reference to a list. The table of vessel types below is illustrative, but is not exhaustive.

The key aspects are transport and necessarily provided at sea. PARA19 (1)(d) will be interpreted in light of the underlying purpose of tonnage tax, which is to promote the competitiveness of United Kingdom shipping internationally, recognising the existence of tonnage taxes and other special shipping regimes that exist elsewhere. Encouraging and preserving economic activity in the UK and the promotion of high environmental standards in the maritime industry will be important factors in applying the legislation.

Service vessels, some examples below, will in general qualify, subject to the special provisions on offshore installations in controlled waters and tankers dedicated to particular oil fields (see TTM11130).

Mobile drilling rigs, floating production, storage and offloading vessels (FPSOs) and flotels (floating hotels, accommodation vessels), as mentioned at TTM03645, continue to be excluded when related to the exploitation of mineral resources. Accommodation vessels that support workers in other operations, such as wind farm servicing, enabling them to live and work offshore as part of necessary transport arrangements ("walk to work") are not excluded.

Any issues regarding particular vessel types may be referred to the Tonnage Tax Technical Adviser, see TTM01120.

• Cable layer

• Cable repair

• Crane/Derrick barge

• Diving support vessel

• Fire-fighting vessel

• Oceanographic vessel

• Oil-well stimulation vessel

• Pile driving vessel

• Pilot vessel (if more than 100 gross tons)

• Pipelaying vessel

• Polar research vessel

• Remote operated vehicle support

• Research vessel

• Seismic survey ship

• Survey vessel

• Trenching vessel

• Windfarm servicing vessels.

Well-boats used to transport live fish in aquaculture are not regarded as fishing boats or factory ships.

See also TTM11001 onwards for ships engaged in offshore activities. Profits from offshore activities are charged to tax under the normal Corporation Tax regime.