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HMRC internal manual

Oil Taxation Manual

Non-Residents Working on the UK Continental Shelf: Divers - Local Compliance (SME Interventions) Office Aberdeen Responsibilities

Identification of cases

Aberdeen office identifies and assesses divers & diving supervisors affected by ITTOIA2005\S15. The majority of diving contractors working in the territorial sea of the UK or its continental shelf are UK resident companies. Non-resident companies operating through UK permanent establishments etc. may be identified from trade directories. Returns under S77I of TMA70 provide further information and these are copied to Aberdeen office.

Return of payments to Divers

Aberdeen office obtains from diving contractors regular returns of payments made to divers & diving supervisors affected by ITTOIA2005\S15. This office then seeks the necessary returns and accounts to compute income tax liabilities. Any HMRC determinations of tax due are based on the contractor’s returns.

DTR claims

Aberdeen also deals with claims for Double Taxation Relief from non-resident divers & supervisors. In deciding what relief, if any, is due the rules relating to employees (within the Dependent Personal Services Article or Income from Employment Article) apply.