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HMRC internal manual

Oil Taxation Manual

Non-Residents Working on the UK Continental Shelf: Scope of Exploration or Exploitation Activities - Meaning of “Exploration or Exploitation Activities”

“Exploration or exploitation activities” are defined in CTA09\S1313(3), ITTOIA05\S874(2) and ITEPA03\S41(2) as “activities carried on in connection with the exploration or exploitation of so much of the seabed and subsoil and their natural resources as is situated in the UK or a designated area”. The definition is not restricted to oil and gas and therefore equally applies to activities related to other natural resources.

The above definition embraces:

  1. The seabed of the Territorial Sea and designated areas, and its natural resources:
  2. The subsoil under the seabed in the UK Territorial Sea and designated areas, and its natural resources;

The meaning of the phrase “designated area” is discussed in OT40650. The interpretation of the phrase “carried on in connection with” is discussed in OT40700.