HMRC v Dolphin Drilling Ltd

In HMRC v Dolphin Drilling Ltd [2024 EWCA Civ 1 (11 January 2024) the Court of Appeal (CA) allowed HMRC’s appeal ruling that the ‘hire cap’ under the oil contractor regime applied to restrict the deduction available to the company for the cost of chartering a tender support vessel.

Dolphin chartered the vessel the Borgsten from an associated company to provide services to the Dunbar oil platform under a contract with the platform’s operator Total. The services included supplying water compressed air and other chemicals to the platform and providing warehousing heliport and storage as well as accommodation for around 50 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...

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