51茶馆

Since April 1973 the scope of UK tax liability has been extended for income from 鈥渆xploration or exploitation rights鈥� so that:

1. for the purposes of income tax or corporation tax such income is treated as profits or gains from property in the UK; and
2. for the purposes of corporation tax such income is treated as profits or gains of a trade carried on in the UK through a branch or agency.

Double Taxation Agreements may affect the scope of charge to UK tax (see OT41500+).

Under CTA09\S1313(3) & ITTOIA05\S874鈥漞xploration or exploitation rights鈥� are:

1. Rights to assets to be produced by activities carried on in connection with the exploration or exploitation of so much of the seabed and sub-soil and their natural resources as is situated in the UK or the UK sector of the continental shelf;
2. Interests in or to the benefit of assets within (a) above.

Profits from such 鈥渆xploration or exploitation rights鈥� are treated for the purposes of income tax and corporation tax as arising from activities or property in the UK under CTA09\S1313(1) & ITTOIA05\S874(1).

Profits from 鈥渆xploration or exploitation rights鈥� for non-resident UK companies are treated for the purposes of corporation tax as profits of a trade carried on in the UK through a branch or agency, even if that income does not accrue in the course of a trade, under CTA09\S1313(2).

Double Taxation Agreements with particular countries have differing definitions of the UK - see OT41510.