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HMRC internal manual

Employment Income Manual

Tax treatment of workers in the North Sea and other offshore oil and gas fields: effect of double taxation agreements

Many Double Taxation Agreements (DTAs) have an employment income or dependent services article, which exempts non-residents from United Kingdom tax provided they work for an overseas employer and are in the United Kingdom for less than half the year (see DT220). Most DTAs use for this purpose a definition of the United Kingdom that includes the designated areas of the continental shelf, but some of the older ones do not. Where an agreement does not specifically mention the continental shelf, employees working there should not be regarded as working in the UK for the purposes of that particular DTA.