Taxation logo taxation mission text

Since 1927 the leading authority on tax law, practice and administration

No deduction available

13 September 2010
Issue: 4272 / Categories: Tax cases
Wright, Whittle and Kenrick (deceased) (TC655)

Three taxpayers claimed the foreign earnings deduction for seafarers in respect of their employment. They were employed on a movable unpowered platform that was moved and anchored near drilling platforms.

HMRC accepted that the vessel was a ship.

However they also deemed it to be an offshore installation which paradoxically meant that it was deemed not to count as a ship for the purposes of the deduction.

The appellants argued that the vessel was not a drilling rig and could not function as such.

The First-tier Tribunal said that the appellants’ argument was true but not relevant: the vessel was used entirely in connection with drilling wells for exploring and exploiting mineral resources.

It was also used to provide ancillary services including water mud cement and to provide accommodation for the drilling workers.

The judge accepted that the vessel...

If you or your firm subscribes to Taxation.co.uk, please click the login box below:

If you are not a subscriber but are a registered user or have a free trial, please enter your details in the following boxes:

Alternatively, you can register free of charge to read a limited amount of subscriber content per month.
Once you have registered, you will receive an email directing you back to read this item in full.

Please reach out to customer services at +44 (0) 330 161 1234 or 'customer.services@lexisnexis.co.uk' for further assistance.

back to top icon