Michael Thompson and Jenny Doak on the rules affecting exploration and exploitation of oil and gas reserves beyond the UK’s territorial waters.
Generally speaking non-resident companies are subject to UK corporation tax only if they carry on a trade in the UK (that is either onshore or within 12 miles of the coast) and that trade is carried on through a UK permanent establishment. There are also territorial limitations on the scope of UK income tax and capital gains tax.
There are however special rules which extend the ambit of UK direct taxes to cover profits of non-UK...
