HMRC internal manual

Oil Taxation Manual

OT42550 - Non-Residents Working on the UK Continental Shelf: Capital Allowances - Plant & machinery allowances - Disposal events

These are listed at CAA01\S61(1) and the one event that is likely to affect non-resident offshore contractors the most is CAA01\S61(1)(f) - the qualifying activity is permanently discontinued. It is a general rule that where a company ceases to be within the charge to corporation tax in respect of a trade, that trade is treated as permanently discontinued (CTA09\S41(2).That same rule applies to CAA01\S61(1)(f) by virtue of CAA01\S577(2) and therefore when the CTA09\S1313 activity comes to an end, that will trigger a disposal event for capital allowances.