Elyse Waller and Davinder Sahota (EY) review an Upper Tribunal ruling that provides insight on a term used in numerous places in the tax legislation, as well as demonstrating the importance of witness evidence.
The dispute in HMRC v Dolphin Drilling Ltd [2022] UKUT 212 (TCC) concerns the application of the exemption at CTA 2010 s 356LA(3). The exemption states that an asset is not a ‘relevant asset’ if it is reasonable to suppose that its use to provide accommodation for offshore workers is unlikely to be more than incidental to other uses to which the asset is likely to be put. The legislation set out in CTA 2010 Part 8ZA establishes the corporation tax treatment of ‘oil contractor activities’ and operates by ring-fencing the profits from ‘oil contractor activities’ and restricting inter alia the deduction of rental payments on ‘relevant assets’.
Dolphin Drilling Ltd (DDL) provides vessels...
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Elyse Waller and Davinder Sahota (EY) review an Upper Tribunal ruling that provides insight on a term used in numerous places in the tax legislation, as well as demonstrating the importance of witness evidence.
The dispute in HMRC v Dolphin Drilling Ltd [2022] UKUT 212 (TCC) concerns the application of the exemption at CTA 2010 s 356LA(3). The exemption states that an asset is not a ‘relevant asset’ if it is reasonable to suppose that its use to provide accommodation for offshore workers is unlikely to be more than incidental to other uses to which the asset is likely to be put. The legislation set out in CTA 2010 Part 8ZA establishes the corporation tax treatment of ‘oil contractor activities’ and operates by ring-fencing the profits from ‘oil contractor activities’ and restricting inter alia the deduction of rental payments on ‘relevant assets’.
Dolphin Drilling Ltd (DDL) provides vessels...
If you or your firm subscribes to Taxjournal.com, please click the login box below:
If you do not subscribe but are a registered user, please enter your details in the following boxes:
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