[2001] EWCA Civ 1228.

Court of Appeal (Civil Division).

Robert Walker and Longmore LJJ and Carnwath J.

Judgment delivered 27 July 2001.

Income tax – Employment – Foreign earnings deduction – Taxpayers employed 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 employment as seafarers required performance of duties on a ship – Whether jack-up rigs ‘ships’ – Income and Corporation Taxes Act 1988, s. 193(1), Sch. 12, para. 3(2A).

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