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D7.1025 Taxation of offshore activities

Where a qualifying ship (D7.1004) operated by a tonnage tax company is used for offshore activities, special rules apply in relation to:

1. Ìý

   •ÌýÌýÌýÌý profits from the service element of these activities

2. Ìý

   •ÌýÌýÌýÌý capital allowances and

3. Ìý

   •ÌýÌýÌýÌý capital gains

These special rules do not apply if, during any accounting period, the use for offshore activities is for 30 days or less. The 30-day limit applies to the total number of days for all of the company's qualifying ships, not separately for each ship¹. A period of inactivity is not treated as a period of offshore activity unless the inactivity specifically relates to a pending offshore activity and it is impractical for the vessel to do other work in the meantime².

Offshore activities are defined as 'activities in connection with the exploration or exploitation of so much of the seabed or subsoil or their natural resources as is situated in the UK sector of the continental shelf'³.