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HMRC internal manual

Oil Taxation Manual

Non-residents working on the UK continental shelf: organisation of work: Large Business - main responsibilities

Various HMRC Offices may be involved in the establishing, assessment and recovery of tax due from persons carrying on activities, performing duties or disposing of rights connected with the exploration or exploitation of UK natural resources. The main responsibility of the LB Oil & Gas Sector is to identify those non-resident persons:

  • Carrying on activities in the UK Continental Shelf or
  • Disposing of exploration or exploitation rights

who are liable to UK tax solely by virtue of CTA2009\S1313, ITTOIA2005\S874 or TCGA92\S276, to ensure such persons are taxed and to follow up any appeals.

HMRC must ensure the correct profits accruing to a non resident offshore contractor from operations carried on in the UK Continental Shelf are brought within the charge to UK tax. In particular any transactions between a company within the charge to UK tax and a non-resident affiliate not so chargeable should be considered by the company under the transfer pricing legislation when it files the company tax return (see OT43330).

Other offices may be involved as follows:

Category of person Office
UK residents or non-residents who trade through a UK branch or agency. Local offices, LB Oil and Gas or elsewhere in LB.
Divers and diving supervisors. Local Compliance (SME Interventions) Aberdeen
PAYE obligations of resident contractors and the Income Tax liabilities of their employees. Local Compliance offices.
Where there is a separate payroll for the oil and gas workers of a UK resident employer, the scheme will be dealt with at Centre 1    
  PAYE and Income Tax liabilities of employees of non-resident contractors, including the liabilities of workers who carry out their duties on a ship and where those duties are in connection with “exploration or exploitation” activities (see OT40600) Centre 1 (Technical and Foreign)