Definition of a ‘ship’
In T Wright v HMRC (and related appeals) (TC 00655 – 2 September), three individuals, who worked on a ‘semi-submersible self-erecting tender rig’, which was anchored close to drilling platforms and used in connection with those platforms, claimed seafarers’ earnings deduction. HMRC rejected the claims on the basis that the rig was an ‘offshore installation’ and did not qualify as a ‘ship’. The First-Tier Tribunal upheld HMRC’s rulings and dismissed the employees’ appeals.
Why it matters: HMRC has won the great majority of cases concerning the distinction between an ‘offshore installation’ and a ship. There was nothing here to distinguish this case from previous decisions in HMRC’s favour.
Definition of a ‘ship’
In T Wright v HMRC (and related appeals) (TC 00655 – 2 September), three individuals, who worked on a ‘semi-submersible self-erecting tender rig’, which was anchored close to drilling platforms and used in connection with those platforms, claimed seafarers’ earnings deduction. HMRC rejected the claims on the basis that the rig was an ‘offshore installation’ and did not qualify as a ‘ship’. The First-Tier Tribunal upheld HMRC’s rulings and dismissed the employees’ appeals.
Why it matters: HMRC has won the great majority of cases concerning the distinction between an ‘offshore installation’ and a ship. There was nothing here to distinguish this case from previous decisions in HMRC’s favour.