Chancery Division.

[The appeal against this decision is reported at [2000] BTC 282.]

Ferris J.

Judgment delivered 19 April 2000.

Income tax – Relief for foreign earnings – Taxpayers’ employment on ‘jack-up’ drilling rigs – Rigs with retractable legs capable of being towed from place to place – Special provisions for ‘seafarers’ qualifying for relief – Definition of seafarers required employment on ships – Whether jack-up rigs ‘ships’ – Income and Corporation Taxes Act 1988, s. 193(1), Sch. 12, para. 3(2A).

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