In HMRC v Dolphin Drilling Ltd [2025] UKSC 24 (24 June) the Supreme Court (SC) dismissed the company’s appeal deciding that the ‘hire cap’ under the oil contractor regime applied to restrict the deduction available to it for the cost of chartering a tender support vessel (TSV).
Dolphin chartered the vessel the Borgsten from an associated company to provide tender assisted drilling (TAD) services to the Dunbar oil platform as a TSV under a contract with the platform’s operator Total. In addition to the TAD services the Borgsten provided accommodation for around 60 of Total’s personnel who were working on the Dunbar (in addition to the company’s own workers who worked on the Borgsten).
HMRC considered that the hire cap in CTA 2010 s 356N applied but the company argued that the exception given by...
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In HMRC v Dolphin Drilling Ltd [2025] UKSC 24 (24 June) the Supreme Court (SC) dismissed the company’s appeal deciding that the ‘hire cap’ under the oil contractor regime applied to restrict the deduction available to it for the cost of chartering a tender support vessel (TSV).
Dolphin chartered the vessel the Borgsten from an associated company to provide tender assisted drilling (TAD) services to the Dunbar oil platform as a TSV under a contract with the platform’s operator Total. In addition to the TAD services the Borgsten provided accommodation for around 60 of Total’s personnel who were working on the Dunbar (in addition to the company’s own workers who worked on the Borgsten).
HMRC considered that the hire cap in CTA 2010 s 356N applied but the company argued that the exception given by...
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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