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I see no ships
During the years 1991-92 1992-93 and 1993-94 a taxpayer worked on 'jack-up' oil drilling rigs but at those times the Inland Revenue was of the opinion that these were not 'ships' for the purposes of claiming a foreign earnings deduction for seafarers under TA 1988 s 193.
In February 2002 the Revenue stated in Tax Bulletin 57 that prior to 17 March 1998 such rigs would be treated as ships for the purposes of the deduction.
The taxpayer lodged appeals against the assessments for the above-mentioned years. The Revenue refused the appeals as being out of time but on appeal the General Commissioners granted the taxpayer's application. The Revenue sought judicial review on the basis that the Commissioners' decision was ultra vires. The Revenue argued that:
- appeals against the assessments had been settled by agreement under TMA...
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