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HMRC internal manual

Oil Taxation Manual

Non-Residents Working on the UK Continental Shelf: Capital Allowances - Part use of plant & machinery - main rule and single asset rule

A common feature of non-resident offshore contractors is the frequent movement of equipment between the UK Continental Shelf activities and the worldwide trade. The provisions at CAA01\S206 to CAA01\S208 set out the rules for this situation.

The idea is that allowances are to be restricted in a just and reasonable way having regard to the extent to which the plant or machinery is used for purposes other than those of the qualifying activity. In practice this means that allowances are reduced proportionately for non-qualifying use.

CAA01\S206 provides for single asset pools for all expenditure incurred partly for the purposes of the qualifying activity and partly for other purposes.