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HMRC internal manual

Tonnage Tax Manual

Qualifying companies and ships: Offshore installations


An ‘offshore installation’ is defined in CTA10/S1132 as:

  • an offshore installation within the meaning of the Mineral Workings (Offshore Installations) Act 1971, or
  • what would be such an installation if the references in that Act to controlled waters were to any waters.

This definition will include such structures as mobile offshore drilling rigs, Floating Production, Storage and Offloading vessels (FPSO’s) and flotels.

Section 1132 Corporation Tax Act 2010

1132 “Offshore installation”

(1)     In the Corporation Tax Acts “offshore installation” means a structure which is, is to be, or has been, put to a relevant use while in water (see subsections (3) and (4)).

(2)     But a structure is not an offshore installation if—

     (a)     it has permanently ceased to be put to a relevant use,

     (b)     it is not, and is not to be, put to any other relevant use, and  

     (c)     since permanently ceasing to be put to a relevant use, it has been put to a use which is not relevant.

(3)     A use is a relevant use if it is—

     (a)     for the purposes of exploiting mineral resources by means of a well,  

     (b)    for the purposes of exploration with a view to exploiting mineral resources by means of a well,

     (c)     for the storage of gas in or under the shore or the bed of any waters,

     (d)     for the recovery of gas so stored,

     (e)     for the conveyance of things by means of a pipe, or

     (f)     mainly for the provision of accommodation for individuals who work on or from a structure which is, is to be, or has been, put to any of the above uses while in water.

(4)     For the purposes of this section references to a structure being put to a use while in water are to the structure being put to a use while—

     (a)     standing in any waters,

     (b)     stationed (by whatever means) in any waters, or

     (c)     standing on the foreshore or other land intermittently covered with water.

     (5)     In this section “structure” includes a ship or other vessel.


FA00/SCH22/PARA20 (1)(d) and (5) (offshore installation) TTM17106
Excluded vessels TTM03620
Need to consider end-user of chartered ship TTM03675