Arrow Prospectus - PGS

More documents

Recommendations

Info

ARROW SEISMIC ASA – INITIAL PUBLIC OFFERING separately for tax purposes from the main pool of expenditure for as long as the ship is used wholly for trading purposes. A special free deprecation system exists, such that unused allowances which may arise in periods of low profitability can be carried forward and used in addition to the full writing down allowances in the next year. There is further flexibility allowed in that any balancing charge (a clawback of allowances in excess of economic depreciation) arising on disposal of a ship, whereby the charge may be deferred against capital expenditure incurred in the following years. As noted above, ships are not currently included within the long life asset regime and are therefore generally benefit from the standard 25% rate (likely to be 20% from 2008). In addition it is not essential that a ship is in use for allowances to be claimed; as long as it will be brought into use within three years, allowances can be claimed during the construction period. Relief for trading losses Trading losses may be used to relieve other income and chargeable gains for the year in which the loss was incurred and the preceding year, providing the trade was then carried on. Losses may also generally be carried forward without time limit for relief against future trading profits from the same trade, although there can be limitations on change of ownership. A trading loss arising in one company may be offset against the profits (including capital gains) from the same period of another company within a defined 75%-owned group of UK companies subject to some restrictions. The tests for 75% group status, for these purposes, is specifically defined by UK legislation. Assuming that these conditions are met should therefore be possible for all group companies to offset trading losses. Capital gains groups Assets may be transferred between group companies which are in a 75% worldwide group (as defined) without a capital gain arising, if the companies involved are subject to UK corporation tax. For these purposes the 75% group is not the same as the group relief group mentioned above and again is specifically defined in UK legislation. However if the transferee company leaves the group within 6 years, of the transfer date, the transferee is deemed to have disposed of the assets immediately after the start of the accounting period of departure. The valuation for disposal purposes however is taken at the value of the asset immediately following original inter-group transfer. Withholding Taxes Dividends The UK does not impose withholding tax on dividend payments under domestic law. Interest The standard UK withholding tax rate on interest is 20%. This is reduced to zero on application of the UK Norway Tax Treaty subject to certain antiavoidance provisions. Royalties The standard UK withholding tax rate on royalties is 22%. This is reduced to zero on application of the UK Norway Tax Treaty subject to certain anti-avoidance provisions. UK Tonnage Tax Assuming that the relevant companies are, and remain UK resident for corporation tax purposes, the UK tonnage tax regime generally follows a model adopted by several other European countries, under which ordinary profits related to shipping activities are replaced by profits calculated on the basis of net tonnage of qualifying ships. 75
ARROW SEISMIC ASA – INITIAL PUBLIC OFFERING Qualification and entry There are numerous qualifying conditions which must be met in order to enter into the UK tonnage tax regime. A qualifying company or group must elect in order for the regime to apply. This election generally has effect for 10 years, unless a company or group ceases to qualify for the tonnage tax regime. Elections can be made by qualifying companies, within 12 months of becoming a qualifying company and in other specific circumstances. To benefit from the regime a company must be subject to corporate income tax in the UK and operate qualifying ships which are strategically and commercially managed in the UK. A group qualifies if one or more members are qualifying companies. There are restrictions on the percentage of ships that may be time-chartered in and other anti-avoidance provisions. Training requirement Companies are eligible for tonnage tax benefits only if they meet the minimum training obligation. According to the size of the fleet and number of officers employed the company have an obligation to train a specified number of officers. The tonnage tax company’s training plan must be approved before HMRC will permit entrance into the tonnage tax regime. These plans then need to be submitted annually, in order to maintain tonnage tax status. Method of calculation A company or group of companies in relation to which a tonnage tax election has effect is a Tonnage Tax Company (‘TTC’) or Tonnage Tax Group (‘TTG’). For the purposes of corporate income tax, a TTC’s relevant shipping profits (‘RSP’) are replaced by tonnage tax profits (‘TTP’). TTP is calculated by reference to the qualifying daily net tonnage of each ship operated by a TTC. The net tonnage is multiplied by: − − − − £0.60 per 100 tons to 1,000 tons £0.45 per 100 tons between 1,000 tons and 10,000 tons £0.30 per 100 tons between 10,000 tons and 25,000 tons £0.15 per 100 tons above 25,000 tons The TTP is the aggregate of the calculations for each ship. The normal corporation tax rate of 30% (likely to be 28% in 2008) is then applied to the TTP. The relevant shipping profits are made up of four different elements: 1) Income from operating qualifying ships, but excluding certain income, for example income from exploratory operations on the UK continental shelf and certain bareboat chartering income. 2) Dividends received from non-UK shipping companies which would qualify for UK tonnage tax if they were UK resident and subject to UK corporation tax. 3) Interest, foreign exchange gains/losses and profits on interest rate and currency contracts which are so closely related to core tonnage tax activities that they are not treated as investment income; and 4) Gains arising on the disposal of assets used for the tonnage tax trade. 76
Page 1 and 2:
Prospectus Arrow Seismic ASA Offeri
Page 3 and 4:
The contents of this Prospectus are
Page 5 and 6:
7.2 OVERVIEW OF THE GLOBAL SEISMIC
Page 7 and 8:
1. SUMMARY The following summary sh
Page 9 and 10:
• Geopolitical risks - Changes in
Page 11 and 12:
Summary of comparison of three mont
Page 13 and 14:
Subscription Period: From and inclu
Page 15 and 16:
1.11.5 Statements from experts refe
Page 17 and 18:
ARROW SEISMIC ASA - INITIAL PUBLIC
Page 19 and 20:
Page 21 and 22:
Page 23 and 24:
Page 25 and 26: ARROW SEISMIC ASA - INITIAL PUBLIC
Page 75: ARROW SEISMIC ASA - INITIAL PUBLIC
Page 103 and 104: ARROW SEISMIC ASA - APPENDICES APPE
Page 105 and 106: ARROW SEISMIC ASA - APPENDICES APPE
Page 107 and 108: ARROW SEISMIC ASA - APPENDICES 106
Page 127 and 128:
ARROW SEISMIC ASA - APPENDICES 126
Page 129 and 130:
Page 131 and 132:
Page 133 and 134:
Page 135 and 136:
Page 137 and 138:
Page 139 and 140:
ARROW SEISMIC ASA - APPENDICES APPE
Page 141 and 142:
Page 143 and 144:
Page 145 and 146:
Page 147 and 148:
Page 149 and 150:
Page 151 and 152:
Page 153 and 154:
Page 155 and 156:
Page 157 and 158:
Page 159 and 160:
Page 161 and 162:
Page 163 and 164:
ARROW SEISMIC ASA - APPENDICES APPE
Page 165:
Solheimsgt 13, PB 1114 Sentrum, N-5
show all

Arrow Prospectus - PGS

Create successful ePaper yourself

Delete template?

Save as template?