What is an offshore installation under Corporation Tax Act 2010 section 1132?

An offshore installation is any structure, including a ship or vessel, that is currently being used, has previously been used, or is intended to be used for a relevant purpose while positioned in water. The definition is deliberately broad to capture a wide range of structures used in mineral exploitation and related activities under United Kingdom corporation tax law.

What counts as a relevant use for an offshore installation under section 1132?

Relevant uses include exploiting or exploring for mineral resources by means of a well, storing or recovering gas in or under the shore or seabed, conveying things by pipe, and mainly providing accommodation for workers on another structure that is itself being used for any of those purposes while in water.

When does a structure cease to be an offshore installation under CTA 2010 section 1132?

A structure ceases to be an offshore installation only when three conditions are all met: it has permanently ceased all relevant use, it is not intended to be put to any further relevant use in the future, and it has since been put to some other use that is not a relevant use. If any condition is not satisfied, it remains an offshore installation.

What does 'in water' mean for the purposes of section 1132 of the Corporation Tax Act 2010?

'In water' covers a structure standing in any waters, a structure stationed in any waters by whatever means such as anchoring or dynamic positioning, or a structure standing on the foreshore or other land that is intermittently covered with water. This broad definition ensures comprehensive coverage of offshore and coastal structures.

Corporation Tax Act 2010 section 1132

"Offshore installation"

Section 1132 defines what constitutes an "offshore installation" for the purposes of the Corporation Tax Acts, including the types of activities that qualify as relevant use and the circumstances in which a structure ceases to be treated as an offshore installation.

An offshore installation is any structure (including a ship or vessel) that is, has been, or will be used for a relevant purpose while located in water.
Relevant uses include exploiting or exploring for mineral resources via a well, storing or recovering gas under the shore or seabed, conveying things by pipe, or mainly providing accommodation for workers on such structures.
A structure ceases to be an offshore installation if it has permanently stopped all relevant use, will not be put to any further relevant use, and has since been put to a non-relevant use.
"In water" means standing or stationed in any waters by whatever means, or standing on foreshore or other land that is periodically covered by water.

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