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TTM03645 | Qualifying companies and ships: Offshore installations

From HM Revenue & Customs · Tonnage Tax Manual

Definition

An ‘offshore installation’ is defined in CTA10/S1132 as:

  • a structure which is, or is to be, or has been, put to a relevant use 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’s) and flotels. In detail:

1132 “Offshore installation”

(1) In the Corporation Tax Acts “offshore installation” means a structure which is, is to be, or has been, put to a relevant use while in water (see subsections (3) and (4)).

(2) But a structure is not an offshore installation if—

(a) it has permanently ceased to be put to a relevant use,

(b) it is not, and is not to be, put to any other relevant use, and

(c) since permanently ceasing to be put to a relevant use, it has been put to a use which is not relevant.

(3) A use is a relevant use if it is—

(a) for the purposes of exploiting mineral resources by means of a well,

(b) for the purposes of exploration with a view to exploiting mineral resources by means of a well,

(c) for the storage of gas in or under the shore or the bed of any waters,

(d) for the recovery of gas so stored,

(e) for the conveyance of things by means of a pipe, or

(f) mainly for the provision of accommodation for individuals who work on or from a structure which is, is to be, or has been, put to any of the above uses while in water.

(4) For the purposes of this section references to a structure being put to a use while in water are to the structure being put to a use while—

(a) standing in any waters,

(b) stationed (by whatever means) in any waters, or

(c) standing on the foreshore or other land intermittently covered with water.

(5) In this section “structure” includes a ship or other vessel.