D4.1101 UK territorial waters

Corporate tax
Corporate tax | Commentary

D4.1101 UK territorial waters

Corporate tax | Commentary

Division D4.11     Continental Shelf operations

For updates affecting this Division please see Part D0 Updates

Continental Shelf operations

D4.1101 UK territorial waters

There are special provisions1 in respect of activities in UK territorial waters and the UK part of the Continental Shelf.

These involve an extension in the territorial jurisdiction of UK tax law which previously had generally been limited to the land surface of England and Wales, Scotland and Northern Ireland. This is achieved first by regarding UK territorial waters as part of the UK and, secondly, by treating those activities carried out on the UK part of the Continental Shelf over which the UK has jurisdiction (ie exploration and exploitation of the sea bed and subsoil and their natural resources) as carried on in the UK.

For the purposes of income tax, capital gains tax and corporation tax the territorial waters of the UK up to the 12 mile limit are to be regarded as part of the UK2.

In this part of the legislation a number of special terms are used as follows3:


    (a)     'UK sector of the continental shelf'

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