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HMRC internal manual

Tonnage Tax Manual

Qualifying companies and ships: Tankers dedicated to a particular oilfield


Whether or not a tanker is dedicated to a particular oil field is determined in accordance with the Oil Taxation Act 1983 (dedicated mobile assets).

All of this is related to Petroleum Revenue Tax and clearly the only taxpayers that could possibly have dedicated tankers are oil licensees dealt with by LB (Oil & Gas).

Section 2 OTA 1983

(1) For the purposes of this Act and Part 1 of the principal Act a mobile asset becomes dedicated to a particular oil field in a claim period if:
  1. the asset is used in connection with the field during the whole, or part of, a claim period; and
  2. the asset was not, at the beginning of that period, already dedicated to that field; and
  3. at the end of that period it is reasonable to make the assumptions in subsection (2) below.

(2) The assumptions referred to in paragraph (c) of subsection (1) above are:

  1. that during the whole or substantially the whole of the relevant period, the asset will be used in connection with the field referred to in that subsection (whether or not that use will be exclusive to that field); and
  2. that the main use of the asset during the whole of the relevant period will be in connection with that field or with two or more oil fields of which that field is one.  


FA00/SCH22/PARA20 (1)(e) + (6) (dedicated tankers) TTM17106
Excluded vessels TTM03620
Need to consider end-user of chartered ship TTM03675