Corporation Tax Act 2010 section 356LA

"Relevant asset"

Section 356LA defines what counts as a "relevant asset" for the purposes of the oil contractor hire cap rules, setting out the types of mobile structures that fall within scope and the conditions that must be met.

  • A relevant asset is a mobile structure — including ships and vessels — that can be moved without major dismantling and is capable of being used either to drill for oil or to provide accommodation for offshore workers operating from another structure involved in exploration or exploitation activities.
  • If a structure's use as accommodation for offshore workers is only incidental to its other uses, it is excluded from the definition.
  • Two further conditions must both be met: the asset (or part of it) must be leased from an associated person other than the contractor (Condition A), and the asset must have a market value of £2,000,000 or more (Condition B).
  • HM Treasury has the power to change the £2,000,000 value threshold by regulations, which may include amending the section itself and making different provision for different circumstances.

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