HMRC has published draft legislation, an explanatory note and a Tax Information and Impact Note (TIIN) for UK oil and gas – offshore bareboat chartering
The measure is effective in respect of leasing payments made on and after 1 April 2014.
The new rules will cap the tax deduction available for a bareboat (or similar) leasing payment in the UK Continental Shelf (UKCS) to an associated person, where this arises as part of a composite service. It is meant to ensure that the profits arising from that service are not reduced by unrelated tax relief. Any amounts arising in excess of the cap can be set against non-UKCS activity.
Comments and responses on the draft legislation are due by 9 May 2014. The legislation will be enacted in Finance Bill 2014.
The details are available from GOV.UK https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/299942/20140401_UK_oil_and_gas_-_offshore_bareboat_chartering_-_Technical_note.pdf
