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HMRC internal manual

Tonnage Tax Manual

Background Material: Seafarers

Resident, but not ordinarily resident, in the UKSeafarers who are

resident, but not ordinarily resident, in the UK are chargeable under S15 ITEPA for UK duties and S 26 for non UK duties but only to the extent that those earnings are remitted to the UK (EIM40301).

The United Kingdom means England, Wales, Scotland and Northern Ireland. Section 1013 ITA 2007 extends this for tax purposes to include the territorial sea of the United Kingdom. The territorial sea means all waters within twelve nautical miles of the shore of the United Kingdom. The Isle of Man and the Channel Islands are not part of the United Kingdom. Special rules cover general earnings for duties performed in the UK sector of the continental shelf. General earnings arising from duties performed in a designated area in connection with exploration or exploitation activities are treated as general earnings in respect of duties performed in the United Kingdom (see EIM67100 onwards for full information).

In addition, duties performed on voyages (including part voyages) between UK ports are treated as performed in the UK even if the voyage takes the vessel outside territorial waters and outside a designated area.

Earnings for duties performed on voyages (including part voyages) between two foreign ports or for any other duties performed outside the UK when not engaged on a voyage will be chargeable to the extent that the earnings are actually received in the UK (EIM40301).


Income tax liability of seafarers TTM15300, EIM33000
Guidance for seafarers and employers TTM15300
Not resident in UK TTM15340, EIM42800