Michael King v The Commissioners for HMRC

Facts

Mr Michael King was employed by Helix Offshore Crewing Services Ltd as a services/intervention co-ordinator and carried out all of his duties on board the Q7000, a semi-submersible, dynamically positioned vessel described as a well intervention unit, on which he continues to work. The Q7000 was manufactured in Singapore and, after sea trials, sailed to Nigeria, where its operations began in the tax year 2019/2020. It is owned and operated by companies in the same group as his employer. Mr King claimed Seafarers' Earnings Deduction under Chapter 6 of Part 5 of the Income Tax (Earnings and Pensions) Act 2003 for the tax years ending 5 April 2020, 2021 and 2022. By closure notices dated 1 October 2024, HMRC disallowed those claims and amended his tax liabilities, on the footing that the Q7000 was an "offshore installation" within section 1001 of the Income Tax Act 2007 and therefore not a "ship" for the purposes of the deduction. Mr King appealed to the First-tier Tribunal. Both parties accepted that the Q7000 was a ship as a matter of general law; they disagreed whether it had been put to a "relevant use" and whether it was put to use while standing or stationed in any waters. The appeal was heard on 15 May 2026, Mr King giving evidence by video link.