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HMRC internal manual

Tonnage Tax Manual

HM Revenue & Customs
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Background Material: Seafarers

Not resident in the UKSection 27 ITEMA is the charging provision for general earnings in respect of duties performed in the United Kingdom for any tax year in which the seafarer is not resident in the United Kingdom (see


Seafarers who are not resident in the UK can only be charged under Section 27 in respect of their earnings for duties performed in the UK (see TTM15330).

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. But if the voyage is to a port outside these territorial waters the earnings of a non resident seafarer are not chargeable. For example:

A merchant navy ship steams from Southampton to Ostend. It remains in United Kingdom coastal waters until it is off Harwich. It then leaves territorial waters.

Non resident seafarers are not treated as performing duties in the United Kingdom. Only earnings for duties actually performed in United Kingdom territorial waters are UK-based earnings chargeable under Section 27


Income tax liability of seafarers TTM15300,
Employers of seafarers TTM15380
General earnings TTM42201
Guidance for seafarers and employers TTM15300