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HMRC internal manual

Business Income Manual

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HM Revenue & Customs
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Particular trades: diving industry

S15 Income Tax (Trading and Other Income) Act 2005

Earnings from employment from operations as a diver or diving supervisor in the United Kingdom or a designated area which are concerned with the exploration or exploitation of the seabed, subsoil and their natural resources are taxable as trade profits and not as employment income.

‘Designated area’ means any area designated under S1(7) Continental Shelf Act 1964 and includes, for example, the United Kingdom sector in the North Sea.

All divers and diving supervisors concerned with the exploration and exploitation of the natural oil and gas reserves in the UK Continental Shelf are dealt with by the Divers Unit (LC SME Interventions) in Aberdeen who should be consulted via the GAL “DL-Divers Unit Aberdeen” before any referral to CTISA is made.

Earnings to which the above rules apply are not liable to Class 4 National Insurance Contributions.