SE33221 - Foreign Earnings Deduction (FED) for 'seafarers': meaning of 'seafarer' and 'ship' on and after 17 March 1998

Section 63 Finance Act 1998 and Section 192A(2) and (3) ICTA 1988

Meaning of 'employment as a seafarer'

Employment as a 'seafarer' for Foreign Earnings Deduction (FED) purposes is an:

“employment consisting of the performance of duties on a ship (or of such duties and of others incidental to them).”

Meaning of 'ship'

The general guidance at SE33102 continues to apply after 17 March 1998. A 'ship' must be:

  1. capable of navigation and
  2. used in navigation

'Navigation' means ordered movement across the water. To be a ship, a vessel does not need to have a rudder or its own motive power.

See example of a calculation of a qualifying period by a seafarer at example SE33301.

Statutory exclusion of 'offshore installations'

Section 192A(3) ICTA 1988 introduced a specific exclusion. 'Offshore installations' are not regarded as 'ships' for the purposes of the FED. In consequence, workers on 'offshore installations', no matter what their duties are, are not 'seafarers' and may not claim the Deduction after 17 March 1998.

See SE33222 for guidance on 'off-shore installations'.