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G Gouldson v HMRC

In G Gouldson v HMRC (Upper Tribunal – 21 June) an individual (G) was employed on a ‘multipurpose platform supply vessel’ which provided accommodation for people constructing offshore oil tanks. He claimed seafarers’ earnings deduction for 2004/05 to 2006/07 inclusive.

HMRC rejected the claim on the basis that the vessel was an ‘offshore installation’ and was not within the definition of a ‘ship’.

The First-tier Tribunal upheld HMRC’s ruling and dismissed G’s appeal and the Upper Tribunal upheld this decision.

Judge Bishopp held that the purpose of the legislation was ‘to deny relief to those who are working on essentially fixed installations used directly or indirectly for mineral exploitation.’

Why it matters: ITEPA 2003 s 385 defines a ship and distinguishes it from an ‘offshore installation’. HMRC have won the great majority of cases concerning...

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