Oil Taxation Manual

OT26603 - Capital Allowances: Long Life Assets - Expenditure excluded from being on Long Life Assets - Ships and offshore installations

CAA01\S94

CAA01\S94 excludes from LLA바카라 사이트檚 expenditure incurred before 1 January 2011 on the provision of a ship of a seagoing kind and the ship is not an offshore installation (see CA23730).

Floating Production Storage and Offloading Vessels (FPSO바카라 사이트檚) may appear to be ships but whether or not they are will be dependent on the facts of each case (see CA25100).

However, the CAA01\S94 exclusion from LLA바카라 사이트檚 does not apply if the 바카라 사이트渟hip바카라 사이트� falls within the definition of an 바카라 사이트渙ffshore installation바카라 사이트� for the purposes of the Mineral Workings (Offshore installations) Act 1971. This Act defines offshore installation as meaning:

• 바카라 사이트渁ny installation which is or has been maintained, or is intended to be established, for the carrying on of any activity to which this Act applies바카라 사이트�.

As the activities to which the Act applies include:

바카라 사이트渢he exploitation or exploration of mineral resources in or under the shore or bed of controlled waters바카라 사이트�,

and as installation includes:

바카라 사이트渁ny floating structure or device maintained on a station by whatever means바카라 사이트�.

HMRC consider that Floating Production Storage and Offloading Vessels (FPSO바카라 사이트檚) fall within the definition of long life assets if their expected working life when new is at least 25 years.