TTM11200 - Offshore Activities: Offshore profits

Outline

Definition

The term ‘offshore profits’ is used in paragraph 107(1) to refer to the profits made whilst a ship is engaged in offshore activities.

For example consider a company operating a seismic survey ship:

  • if it is shooting (collecting) seismic data in an area designated by the UK, the profits arising will be ‘offshore profits’, but
  • if it is shooting seismic data in an area designated by Norway , the profits arising will not be ‘offshore profits’.
  • See also Example 3 in TTM11220.

Special computational rules

  • Special computational rules are set out in TTM11210.

Restriction on deduction of training expenses

No deduction may be made by a company in computing its profits from offshore activities in respect of expenditure incurred in meeting the training requirement, per paragraph 114(5).

However, a special allowance in respect of costs, that would not have had to be provided if offshore activities were not tonnage tax activities, may be deducted from the corporation tax payable, (see TTM11400 onwards).

References

FA00/SCH22/PARA107 (profits computed on ordinary rules)

TTM17611

FA00/SCH22/PARA108 (application of ring fence provisions)

TTM17616

Meaning of ‘offshore activities’

TTM11010