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HMRC internal manual

Oil Taxation Manual

Capital gains: non residents: non-dedicated mobile assets

Non-dedicated mobile assets, such as mobile drilling rigs or support vessels of the kind which move in and out of UK waters, are not within the TCGA92\S276(5)(b) definition. This ensures that a non-resident offshore contractor who owns and operates these types of vessels and is taxable in the UK only because of the provisions at CTA10\S1313 does not have any liability on capital gains arising on the disposal of such vessels. If, however, the non-resident offshore contractor is carrying on a trade in the UK through an actual branch or agency and the asset meets the criteria at OT30823, then a charge will arise under the general provisions in TCGA92\S10 when the asset is disposed of.