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HMRC internal manual

Oil Taxation Manual

Taxation of Non-residents under Section 830 ICTA 1988: Double Taxation Agreements - Measurement of duration

Where a double taxation treaty has an Offshore Activities Article (see OT41560), then the definition of a day may become crucial. HMRC consider that in assessing whether “offshore activities are carried on ….. for a period or periods not exceeding in the aggregate 30 days …”. A day means any part of a day. This is in line with guidance in the OECD Commentary on both the Permanent Establishment and income from Employment Articles where duration is an element to be considered in liability.